SecProbe.io

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 August 12, 2025

Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
1441 Broadway , Suite 5116
New York , NY 10018

 Re: Ideanomics, Inc.
 Form 10-K for the fiscal year ended December 31, 2023
 File No 1-35561
Dear Alfred Poor:

 We issued comments on the above captioned filing on July 29, 2024. On
July 22,
2025, we issued a follow-up letter informing you that comments remained
outstanding and
unresolved, and absent a substantive response, we would act consistent with our
obligations
under the federal securities laws.

 As you have not provided a substantive response, we are terminating our
review and
will take further steps as we deem appropriate. These steps include releasing
publicly,
through the agency's EDGAR system, all correspondence, including this letter,
relating to the
review of your filing, consistent with the staff's decision to publicly release
comment and
response letters relating to disclosure filings it has reviewed.

 Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at
202-551-3301
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
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<TEXT>
 July 22, 2025

Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
1441 Broadway , Suite 5116
New York , NY 10018

 Re: Ideanomics, Inc.
 Form 10-K for the fiscal year ended December 31, 2023
 File No 1-35561
Dear Alfred Poor:

 We issued comments to you on the above captioned filing on July 29,
2024. As of the
date of this letter, these comments remain outstanding and unresolved. We
expect you to
provide a complete, substantive response to these comments by August 5, 2025.

 If you do not respond, we will, consistent with our obligations under
the federal
securities laws, decide how we will seek to resolve material outstanding
comments and
complete our review of your filing and your disclosure. Among other things, we
may decide
to release publicly, through the agency's EDGAR system, all correspondence,
including this
letter, relating to the review of your filings, consistent with the staff's
decision to publicly
release comment and response letters relating to disclosure filings it has
reviewed.

 Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at
202-551-3301
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

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Document

                                                        August 12, 2024

U.S. Securities and Exchange Commission

Washington, D.C. 20549

Attn:    Mr. Charles Eastman and Mr. Martin James

    Division of Corporation Finance

    Office of Manufacturing

Re:     Ideanomics, Inc.

    Form 10-K for the fiscal year ended December 31, 2023

    File No 1-35561

Ladies and Gentlemen:

We are in receipt of your letter dated July 29, 2024, related to the limited review by the staff of the Securities and Exchange Commission of the Form 10-K for the fiscal year ended December 31, 2023, of Ideanomics, Inc. (the “Company”).  Set forth below is the staff’s comment in bold followed by the Company’s response.

Form 10-K for the fiscal year ended December 31, 2023

General

1.     We note the Forms NT 10-Q and NT 10-Q/A you filed on May 15, 2024, and May 16, 2024, respectively. Please tell us when you plan to file your Form 10-Q for the quarterly period ended March 31, 2024.

At this time, the Company cannot state definitively when it will be able to file its Quarterly Reports on Form 10-Q for the quarterly periods ended March 31 and June 30, 2024.  The Company is pursuing, through potential funding sources and potential divestitures under negotiation, bringing in sufficient capital required to continue operations, including the costs related to filing such Reports and associated professional service fees. We continue to push for a resolution on these potential avenues of financing as soon as possible and will advise you immediately as and when we are in position to anticipate filing.

Sincerely,

Alfred P. Poor

Chief Executive Officer

1441 Broadway, Suite #5116, New York, NY 10018 | ideanomics.com

July 29, 2024
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
1441 Broadway , Suite 5116
New York , NY 10018
Re:Ideanomics, Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No 1-35561
Dear Alfred Poor:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2023
General
1.We note the Forms NT 10-Q and NT 10-Q/A you filed on May 15, 2024 and May 16,
2024, respectively. Please tell us when you plan to file your Form 10-Q for the quarterly
period ended March 31, 2024.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 with
any questions.
Sincerely,

July 29, 2024
Page 2
Division of Corporation Finance
Office of Manufacturing

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Ideanomics, Inc.

1441 Broadway, Suite 5116

New York, NY 10018

January 31, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F. Street, N.E.

Washington, D.C. 20549

    Re:
    Ideanomics, Inc.

    Registration Statement on Form S-1

    File Number 333-269001

Ladies and Gentlemen:

Ideanomics, Inc. (the
 “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”)
take appropriate action to cause the above-referenced Registration Statement on Form S-1 to become effective
on February 1, 2023, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant
may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes William N. Haddad of Venable LLP,
counsel to the Registrant, to make such request on its behalf.

Once the Registration Statement
has been declared effective, please orally confirm that event with William N. Haddad of Venable LLP, counsel to the Registrant, at (212)
503-9812.

    Very truly yours,

    Ideanomics, Inc.

    By:

    /s/ Alfred P. Poor

    Name:
    Alfred P. Poor

    Title:
    Chief Executive Officer

    cc:
    Paula Whitten-Doolin, Ideanomics, Inc.

    William N. Haddad, Venable LLP

CORRESP
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T 212.503.9812

F 212.307.5598

wnhaddad@venable.com

January 20, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, DC 20549

Attention: Eranga Dias

Asia Timmons-Pierce

 Re: Ideanomics, Inc.

    Registration Statement on Form S-1

    Filed December 23, 2022

    File No. 333-269001

Ladies and Gentlemen:

On behalf of our client, Ideanomics,
Inc. (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by
the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission in its comment
letter dated January 19, 2023 (the “Comment Letter”) with respect to the above-referenced Registration Statement on
Form S-1 (“Registration Statement”). In response to the Comment Letter, the Company is filing Amendment No. 1
to the Registration Statement (the “Amended Registration Statement”) through EDGAR.

For your convenience, we have
set forth each comment of the Staff from the Comment Letter in bold type below followed by the Company’s response thereto.

Registration Statement on Form S-1 Filed 12/23/2022

Cover Page

 1. Please disclose that you have received a notice from Nasdaq indicating that the company was no longer
in compliance with the audit committee requirements as set forth in Nasdaq Listing Rule 5605. Please provide an update on the status of
this notice. Please also disclose the status of the notice of non-compliance with the Nasdaq requirements pertaining to the minimum bid
price for listed stock pursuant to Nasdaq Listing Rule 5550(a)(2). Please also add risk factor disclosure related to potential delisting
from the exchange.

Response: In response to the
Staff’s comment, the Company has revised its disclosures on the cover page of the Amended Registration Statement.

U.S. Securities and Exchange Commission

January 20, 2023

Page 2

Status of Previously Announced Acquisitions,
page 67

 2. Please update disclosure regarding the VIA Motors transaction to accurately reflect the current status
of the transaction.

Response: In response to the
Staff’s comment, the Company has revised its disclosures on page 69 of the Amended Registration Statement.

Executive Compensation, page 94

 3. Please update disclosure to include compensation information for the year ended December 31, 2022.

Response: In response to the
Staff’s comment, the Company has revised its disclosures beginning on page 96 of the Amended Registration Statement.

We hope that the foregoing
and the Company’s revised disclosures have been responsive to the Staff’s comments. Should you have any questions or comments
relating to this letter, kindly contact the undersigned at 212-503-9812.

   Very truly yours,

    /s/ William N. Haddad

    William N. Haddad

 cc: Alfred P. Poor, Ideanomics, Inc.

    Stephen Johnston, Ideanomics, Inc.

    Paula Whitten-Doolin, Ideanomics, Inc.

United States securities and exchange commission logo
January 19, 2023
Alfred Poor
Chief Executive Officer
IDEANOMICS, INC.
1441 Broadway, Suite 5116
New York, NY 10018
Re:Ideanomics, Inc.
Registration Statement on Form S-1
Filed December 23, 2022
File No. 333-269001
Dear Alfred Poor:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1 Filed 12/23/2022
Cover Page
1.Please disclose that you have received a notice from Nasdaq indicating that the company
was no longer in compliance with the audit committee requirements as set forth in Nasdaq
Listing Rule 5605.  Please provide an update on the status of this notice. Please also
disclose the status of the notice of non-compliance with the Nasdaq requirements
pertaining to the minimum bid price for listed stock pursuant to Nasdaq Listing Rule
5550(a)(2). Please also add risk factor disclosure related to potential delisting from the
exchange.

 FirstName LastNameAlfred Poor
 Comapany NameIDEANOMICS, INC.
 January 19, 2023 Page 2
 FirstName LastName
Alfred Poor
IDEANOMICS, INC.
January 19, 2023
Page 2
Status of Previously Announced Acquisitions, page 67
2.Please update disclosure regarding the VIA Motors transaction to accurately reflect the
current status of the transaction.
Executive Compensation, page 94
3.Please update disclosure to include compensation information for the year ended
December 31, 2022.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Eranga Dias at 202-551-8107 or Asia Timmons-Pierce at 202-551-
3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
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	IDEANOMICS,
INC.

55 Broadway, 19th Floor

New York, NY 10006

December 19, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Mrs. Jennifer Lopez Molina & Ms. Alyssa Wall

    Re:
    Ideanomics, Inc.

    Registration Statement on Form S-1

    File Number 333-267547

    REQUEST FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness of
the Company’s Registration Statement on Form S-1, File Number 333-267547, so that it will be declared effective on Tuesday December
20, 2022 at 9:05 a.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company acknowledges
that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •

    the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact our legal counsel, William N.
Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

    Very truly yours,

    Ideanomics, Inc.

    By:

    /s/ Alfred Poor

    Name:

    Alfred Poor

    Title:

    Chief Executive Officer

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T 212.503.9812

F 212.307.5598

wnhaddad@venable.com

December 5, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, DC 20549

 Attention: Alyssa Wall

Jennifer López Molina

 Re: Ideanomics, Inc.

    Amendment No. 1 to Registration Statement on Form S-1

    Filed November 7, 2022

    File No. 333-267547

Ladies and Gentlemen:

On behalf of our client, Ideanomics, Inc.
(the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by the staff
(the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission in its comment letter
dated December 1, 2022 (the “Comment Letter”) with respect to the above-referenced Registration Statement on Form S-1
(“Registration Statement”). In response to the Comment Letter, the Company is filing Amendment No. 2 to the Registration
Statement (the “Amended Registration Statement”) through EDGAR.

For your convenience, we have set forth each comment
of the Staff from the Comment Letter in bold type below followed by the Company’s response thereto.

Amendment No. 1 to Registration
Statement on Form S-1 filed November 7, 2022

Cover Page

 1. We note your revised disclosure in response to comment 2. Please revise where you discuss Holding Foreign Companies Accountable
Act to also discuss the Accelerating Holding Foreign Companies Accountable Act.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on the cover page of the Amended Registration Statement.

U.S. Securities and Exchange Commission

December 5, 2022

Page 2

Control by the Chinese Government,
Permission or Approval by the Chinese Government., page 18

 2. We note your amended disclosure in response to comment 9. Please clearly indicate in your disclosure whether you relied on an opinion
of counsel when determining what permissions and approvals are required in connection with the operation of the PRC subsidiaries. Additionally,
please disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your
business. Please also discuss the risks related to obtaining/not obtaining required permissions and approvals from Chinese authorities
in your Risk Factors section.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on pages 19, 28, 29, and 30 of the Amended Registration Statement.

Risk Factors Summary

Risk related to our operations
in China., page 19

 3. We note your response to comment 8 and your revised disclosure that you are not a China-based issuer. Such statement does not appear
to be consistent with your disclosure that “a significant portion of our current operations is located in mainland China and a significant
portion of our revenue is derived from mainland China.” Please revise.

As a related matter, please also revise your disclosure
so each summary risk factor related to your operations in China includes a cross-reference to the relevant individual detailed risk factor.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on the cover page and on pages 19 and 27 of the Amended Registration Statement.

Risks Related to Doing Business
in China

In light of recent events indicating
greater oversight by the CAC..., page 26

 4. We note your amended disclosure in response to comment 13. Please clearly indicate in your disclosure whether you relied on an
opinion of counsel when determining whether PRC laws and other obligations applied to your business and this offering.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on pages 28 and 29 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

December 5, 2022

Page 3

General

 5. Please expand your disclosure throughout the registration statement to clarify that the legal and operational risks associated
with operating in China also apply to your operations in Hong Kong.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on the cover page and on page 8 of the Amended Registration Statement.

 6. We note your revised disclosure in response to comments 3 and 10. Please clarify which entity made the cash transfers discussed.

As a related matter, we note your disclosure that the
company does not have records of cash transfers in and out of the VIEs for the fiscal year 2019 in possession and your response to comment
11 in your letter dated November 7, 2022 that source records from that period were maintained by a third party provider in China
with whom you no longer continue a service relationship. Please discuss in your risk factors whether and how such loss of records impacts
your business and disclosure, controls and procedures.

Response: In response to the Staff’s comment,
the Company has revised its disclosures on the cover page and on pages 12 and 23 of the Amended Registration Statement. Additionally,
the Company respectfully submits that following the Company’s response in its letter dated November 7, 2022, the Company used
its best efforts to obtain the information previously requested by the Staff in comment 11 in order to enhance its disclosures in the
Amended Registration Statement. Accordingly, the Company additionally revised its disclosures on pages 12 and 13 of the Amended Registration
Statement.

We hope that the foregoing
and the Company’s revised disclosures have been responsive to the Staff’s comments. The Company respectfully requests to
expedite the review process of the Amended Registration Statement to secure additional capital in a timely manner so as not to
dissuade interested investors in challenging market conditions. Should you have any questions or comments relating to this letter,
kindly contact the undersigned at 212-503-9812.

    Very truly yours,

    /s/ William N. Haddad

    William N. Haddad

cc: Alfred P. Poor, Ideanomics, Inc.

  Stephen Johnston, Ideanomics, Inc.

  Paula Whitten-Doolin, Ideanomics, Inc.

United States securities and exchange commission logo
December 1, 2022
Alfred P. Poor
Chief Executive Officer
Ideanomics, Inc.
1441 Broadway, Suite 5116
New York, NY 10018
Re:Ideanomics, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed November 7, 2022
File No. 333-267547
Dear Alfred P. Poor:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 20, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-1
Cover Page
1.We note your revised disclosure in response to comment 2.  Please revise where you
discuss Holding Foreign Companies Accountable Act to also discuss the Accelerating
Holding Foreign Companies Accountable Act.
Control by the Chinese Government, Permission or Approval by the Chinese Government., page
18
2.We note your amended disclosure in response to comment 9.  Please clearly indicate in
your disclosure whether you relied on an opinion of counsel when determining what
permissions and approvals are required in connection with the operation of the PRC

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 December 1, 2022 Page 2
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
December 1, 2022
Page 2
subsidiaries.  Additionally, please disclose each permission or approval that you or your
subsidiaries are required to obtain from Chinese authorities to operate your business.
Please also discuss the risks related to obtaining/not obtaining required permissions and
approvals from Chinese authorities in your Risk Factors section.
Risk Factors Summary
Risk related to our operations in China., page 19
3.We note your response to comment 8 and your revised disclosure that you are not a
China-based issuer.  Such statement does not appear to be consistent with your disclosure
that "a significant portion of our current operations is located in mainland China and a
significant portion of our revenue is derived from mainland China."  Please revise.

As a related matter, please also revise your disclosure so each summary risk factor related
to your operations in China includes a cross-reference to the relevant individual detailed
risk factor.
Risks Related to Doing Business in China
In light of recent events indicating greater oversight by the CAC..., page 26
4.We note your amended disclosure in response to comment 13.  Please clearly indicate in
your disclosure whether you relied on an opinion of counsel when determining whether
PRC laws and other obligations applied to your business and this offering.
General
5.Please expand your disclosure throughout the registration statement to clarify that the
legal and operational risks associated with operating in China also apply to your
operations in Hong Kong.
6.We note your revised disclosure in response to comments 3 and 10.  Please clarify which
entity made the cash transfers discussed.

As a related matter, we note your disclosure that the company does not have records of
cash transfers in and out of the VIEs for the fiscal year 2019 in possession and your
response to comment 11 in your letter dated November 7, 2022 that source records from
that period were maintained by a third party provider in China with whom you no longer
continue a service relationship.  Please discuss in your risk factors whether and how such
loss of records impacts your business and disclosure, controls and procedures.

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 December 1, 2022 Page 3
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
December 1, 2022
Page 3
            Please contact Alyssa Wall at 202-551-8106 or Jennifer López Molina at 202-551-
3792 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       William N. Haddad, Esq.

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T 212.503.9812

F 212.307.5598

wnhaddad@venable.com

November 7, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, DC 20549

 Attention: Alyssa Wall

Jennifer López Molina

 Re: Ideanomics, Inc.

Registration Statement on Form S-1

Filed September 22, 2022

File No. 333-267547

Dear Ladies and Gentlemen:

On behalf of our client, Ideanomics,
Inc. (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by
the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission in
its comment letter dated October 20, 2022 (the “Comment Letter”) with respect to the above-referenced Registration
Statement on Form S-1 (“Registration Statement”). In response to the Comment Letter, the Company is filing Amendment
No. 1 to the Registration Statement (the “Amended Registration Statement”) through EDGAR.

For your convenience, we have
set forth each comment of the Staff from the Comment Letter in bold type below followed by the Company’s response thereto.

Registration Statement on Form S-1
filed September 20, 2022

Cover Page

1. Please disclose prominently on the prospectus cover page that you are not a Chinese operating company but a Nevada company with
operations conducted by your subsidiaries based in China and that this structure involves unique risks to investors. Please disclose that
investors may never hold equity interests in the Chinese operating companies. Your disclosure should acknowledge that Chinese regulatory
authorities could disallow this structure, which would likely result in a material change in your operations and/or a material change
in the value of the securities you are registering for sale, including that it could cause the value of such securities to significantly
decline or become worthless. Provide a cross-reference to your detailed discussion of risks facing the company and
the offering as a result of this structure.

U.S. Securities and Exchange Commission

November 7, 2022

Page 2

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page.

2. Provide prominent disclosure about the legal and operational risks associated with being based in or having a significant portion
of the company’s operations in China. Your disclosure should make clear whether these risks could result in a material change in
your operations and/or the value of the securities you are registering for sale or could significantly limit or completely hinder your
ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.
Your disclosure should address how recent statements and regulatory actions by China’s government, such as those related to the
use of variable interest entities and data security or anti-monopoly concerns, have or may impact the company’s ability to conduct
its business, accept foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether your auditor is subject
to the determinations announced by the PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies Accountable Act and
related regulations will affect your company. Your prospectus summary should address, but not necessarily be limited to, the risks highlighted
on the prospectus cover page.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on pages 19, and 24 of the Amended Registration Statement.

3. Provide a description of how cash is transferred through your organization and disclose your intentions to distribute earnings.
State whether any transfers, dividends, or distributions have been made to date between the Nevada company, its subsidiaries, previous
consolidated VIEs or to investors and quantify the amounts where applicable. Provide cross-references to the condensed consolidating schedule
and the consolidated financial statements. The disclosure here should not be qualified by materiality.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on pages 11 and 12 of the Amended Registration Statement.

4. Please amend your disclosure here and in the summary risk factors and risk factors sections to state that, to the extent cash and
assets in the business are in the PRC/Hong Kong or a PRC/Hong Kong entity, the funds and assets may not be available to fund operations
or for other use outside of the PRC/Hong Kong due to interventions in or the imposition of restrictions and limitations on the ability
of you or your subsidiaries by the PRC government to transfer
cash and assets. On the cover page, provide cross-references to these other discussions. The disclosure here should not be limited by
materiality.

U.S. Securities and Exchange Commission

November 7, 2022

Page 3

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on pages 18, 19, 25, and 26 of the Amended Registration Statement.

5. Discuss whether there are limitations on your ability to transfer cash between you, your subsidiaries or investors. Provide a cross-reference
to your discussion of this issue in your summary, summary risk factors, and risk factors sections, as well.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on pages 12, 15, and 21 of the Amended Registration Statement.

6. To the extent you have cash management policies that dictate how funds are transferred between you, your subsidiaries or investors,
summarize the policies on your cover page and in the prospectus summary, and disclose the source of such policies (e.g., whether they
are contractual in nature, pursuant to regulations, etc.); alternatively, state on the cover page and in the prospectus summary that you
have no such cash management policies that dictate how funds are transferred. Provide a cross-reference on the cover page to the discussion
of this issue in the prospectus summary.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on page 11 of the Amended Registration Statement.

Prospectus Summary, page 6

7. Provide early in the summary a diagram of the company’s corporate structure, identifying the person or entity that owns the
equity in each depicted entity. Identify clearly the entity in which investors are purchasing their interest and the entity(ies) in which
the company’s operations are conducted. Describe the relevant contractual agreements between the entities and how this type of corporate
structure may affect investors and the value of their investment, including how and why the contractual arrangements may be less effective
than direct ownership and that the company may incur substantial costs to enforce the terms of the arrangements. Please also discuss the
evolution of your organizational structure, including the prior VIE structure and why and how that structure changed. Disclose the risks
associated with the change in VIE structure.

U.S. Securities and Exchange Commission

November 7, 2022

Page 4

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 13-17 of the Amended Registration Statement.

8. In your summary of risk factors, disclose the risks that your corporate structure and being based in or having a significant portion
of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement
risks with cross-references to the more detailed discussion of these risks in the prospectus. For example, specifically discuss risks
arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations
in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations
at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could
result in a material change in your operations and/or the value of the securities you are registering for sale. Acknowledge any risks
that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 18, 19, and 22-24 of the Amended Registration Statement. The Company respectfully submits
that it is not a China-based issuer and it is not controlled, directly or indirectly, by the Chinese government which is prominently disclosed
in the prospectus on page 18 of the Amended Registration Statement and renders a portion of the Staff’s comment inapplicable. Accordingly,
the Company is not subject to the rules and regulations of China relating to overseas listing and securities offering and, thus, cannot
acknowledge that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas
and/or foreign investment in China-based issuers could significantly limit or completely hinder the Company’s ability to offer or
continue to offer securities to investors.

9. Disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your
business and to offer the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions
requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental
agency that is required to approve your subsidiaries' operations, and state affirmatively whether you have received all requisite permissions
or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors
if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain
such permissions or approvals in the future. The disclosure here should not be qualified by materiality.

U.S. Securities and Exchange Commission

November 7, 2022

Page 5

Response: In response to the Staff’s comment,
the Company has revised the disclosure on page 18 of the Amended Registration Statement.

10. Provide a clear description of how cash is transferred through your organization. Quantify any cash flows and transfers of other
assets by type that have occurred between the Nevada company and its subsidiaries, and direction of transfer. Quantify any dividends or
distributions that a subsidiary has made to the Nevada company and which entity made such transfer, and their tax consequences. Similarly
quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear
if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your ability to
transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute
earnings from the company, including your subsidiaries, to the parent company and U.S. investors. Please also include disclosure of payments
to and from your VIEs for the year ended December 31, 2019 and provide cross-references to the condensed consolidating schedule and the
consolidated financial statements.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on the cover page and on pages 11 and 12 of the Amended Registration Statement. The Company respectfully
submits that it did not provide the required cross-references to the consolidated financial statements the pertinent information cannot
be found in the Company’s financial statements, due to the fact that such transfers between controlled subsidiaries
are not a required GAAP disclosure.

11. We note that the consolidated VIEs constitute a material part of your consolidated financial statements for the year ended December
31, 2019. Please provide in tabular form a condensed consolidating schedule that disaggregates the operations and depicts the financial
position, cash flows, and results of operations as of the same dates and for the same periods for which audited consolidated financial
statements are required during which you used VIEs. The schedule should present major line items, such as revenue and cost of goods/services,
and subtotals and disaggregated intercompany amounts, such as separate line items for intercompany receivables and investment in subsidiary.
The schedule should also disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that were the primary
beneficiary of the VIEs, and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor
to evaluate the nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts associated
with intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary, additional disclosure
about such amounts should be included in order to make the information presented not misleading.

U.S. Securities and Exchange Commission

November 7, 2022

Page 6

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 11 and 12 of the Amended Registration Statement. The Company respectfully submits that
it was unable to provide a portion of disclosure because the Company does not have records of cash transfers in and out of VIEs for the
fiscal year 2019 in possession, as prominently disclosed on page 12 of the Amended Registration Statement.While the company does not have
records of cash transfers, current books and records show de minimis VIE balance sheet and P&L activity in 2019 prior to deconsolidation.
Sources records were maintained by a third party provider in China, with whom the Company no longer continues a service relationship.
Records maintained are limited to consolidation files, which support the statements as to no change in balance sheet accounts and de
minimis P&L activity in 2019.

Risk Factors, page 9

12. Given the Chinese government’s significant oversight and discretion over the conduct of your business, please revise to highlight
separately the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of the securities you are registering. Also, given recent statements by the Chinese government
indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based
issuers, acknowledge the risk that any such action could significantly limit or completely hinder your ability to offer or continue to
offer securities to investors and cause the value of such securities to significantly decline or be worthless.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 23 and 24 of the Amended Registration Statement. The Company respectfully reiterates its
response to the Staff’s comment 8 and deems a portion of comment 12 inapplicable to the Company.

13. In light of recent events

United States securities and exchange commission logo
October 20, 2022
Alfred P. Poor
Chief Executive Officer
Ideanomics, Inc.
1441 Broadway, Suite 5116
New York, NY 10018
Re:Ideanomics, Inc.
Registration Statement on Form S-1
Filed September 22, 2022
File No. 333-267547
Dear Alfred P. Poor:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Nevada company with operations conducted by your
subsidiaries based in China and that this structure involves unique risks to investors.
Please disclose that investors may never hold equity interests in the Chinese operating
companies. Your disclosure should acknowledge that Chinese regulatory authorities could
disallow this structure, which would likely result in a material change in your operations
and/or a material change in the value of the securities you are registering for sale,
including that it could cause the value of such securities to significantly decline or become
worthless. Provide a cross-reference to your detailed discussion of risks facing the
company and the offering as a result of this structure.

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 October 20, 2022 Page 2
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
October 20, 2022
Page 2
2.Provide prominent disclosure about the legal and operational risks associated with being
based in or having a significant portion of the company’s operations in China. Your
disclosure should make clear whether these risks could result in a material change in your
operations and/or the value of the securities you are registering for sale or could
significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.
Your disclosure should address how recent statements and regulatory actions by China’s
government, such as those related to the use of variable interest entities and data security
or anti-monopoly concerns, have or may impact the company’s ability to conduct its
business, accept foreign investments, or list on a U.S. or other foreign exchange. Please
disclose whether your auditor is subject to the determinations announced by the PCAOB
on December 16, 2021 and whether and how the Holding Foreign Companies
Accountable Act and related regulations will affect your company. Your prospectus
summary should address, but not necessarily be limited to, the risks highlighted on the
prospectus cover page.
3.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings.  State whether any transfers, dividends, or
distributions have been made to date between the Nevada company, its subsidiaries,
previous consolidated VIEs or to investors and quantify the amounts where applicable.
Provide cross-references to the condensed consolidating schedule and the consolidated
financial statements.  The disclosure here should not be qualified by materiality.
4.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash and assets in the business are in the PRC/Hong
Kong or a PRC/Hong Kong entity, the funds and assets may not be available to fund
operations or for other use outside of the PRC/Hong Kong due to interventions in or the
imposition of restrictions and limitations on the ability of you or your subsidiaries by the
PRC government to transfer cash and assets.  On the cover page, provide cross-references
to these other discussions.  The disclosure here should not be limited by materiality.
5.Discuss whether there are limitations on your ability to transfer cash between you,
your subsidiaries or investors.  Provide a cross-reference to your discussion of this issue in
your summary, summary risk factors, and risk factors sections, as well.
6.To the extent you have cash management policies that dictate how funds are transferred
between you, your subsidiaries or investors, summarize the policies on your cover page
and in the prospectus summary, and disclose the source of such policies (e.g., whether
they are contractual in nature, pursuant to regulations, etc.); alternatively, state on the
cover page and in the prospectus summary that you have no such cash management
policies that dictate how funds are transferred.  Provide a cross-reference on the cover
page to the discussion of this issue in the prospectus summary.

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 October 20, 2022 Page 3
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
October 20, 2022
Page 3
Prospectus Summary, page 6
7.Provide early in the summary a diagram of the company’s corporate structure, identifying
the person or entity that owns the equity in each depicted entity.  Identify clearly the entity
in which investors are purchasing their interest and the entity(ies) in which the company’s
operations are conducted.  Describe the relevant contractual agreements between the
entities and how this type of corporate structure may affect investors and the value of their
investment, including how and why the contractual arrangements may be less effective
than direct ownership and that the company may incur substantial costs to enforce the
terms of the arrangements.  Please also discuss the evolution of your organizational
structure, including the prior VIE structure and why and how that structure changed.
Disclose the risks associated with the change in VIE structure.
8.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having a significant portion of the company’s operations in China poses to
investors.  In particular, describe the significant regulatory, liquidity, and enforcement
risks with cross-references to the more detailed discussion of these risks in the
prospectus.  For example, specifically discuss risks arising from the legal system in China,
including risks and uncertainties regarding the enforcement of laws and that rules and
regulations in China can change quickly with little advance notice; and the risk that the
Chinese government may intervene or influence your operations at any time, or may exert
more control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of the
securities you are registering for sale.  Acknowledge any risks that any actions by the
Chinese government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.
9.Disclose each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business and to offer the securities being
registered to foreign investors.  State whether you or your subsidiaries are covered by
permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve your subsidiaries' operations, and state affirmatively whether you
have received all requisite permissions or approvals and whether any permissions or
approvals have been denied. Please also describe the consequences to you and your
investors if you or your subsidiaries: (i) do not receive or maintain such permissions or
approvals, (ii) inadvertently conclude that such permissions or approvals are not required,
or (iii) applicable laws, regulations, or interpretations change and you are required to
obtain such permissions or approvals in the future.  The disclosure here should not be
qualified by materiality.

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 October 20, 2022 Page 4
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
October 20, 2022
Page 4
10.Provide a clear description of how cash is transferred through your organization.  Quantify
any cash flows and transfers of other assets by type that have occurred between the
Nevada company and its subsidiaries, and direction of transfer.  Quantify any dividends or
distributions that a subsidiary has made to the Nevada company and which entity made
such transfer, and their tax consequences.  Similarly quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences.  Your disclosure should
make clear if no transfers, dividends, or distributions have been made to date.  Describe
any restrictions on foreign exchange and your ability to transfer cash between entities,
across borders, and to U.S. investors.  Describe any restrictions and limitations on your
ability to distribute earnings from the company, including your subsidiaries, to the parent
company and U.S. investors.  Please also include disclosure of payments to and from your
VIEs for the year ended December 31, 2019 and provide cross-references to the
condensed consolidating schedule and the consolidated financial statements.
11.We note that the consolidated VIEs constitute a material part of your consolidated
financial statements for the year ended December 31, 2019. Please provide in tabular form
a condensed consolidating schedule that disaggregates the operations and depicts the
financial position, cash flows, and results of operations as of the same dates and for the
same periods for which audited consolidated financial statements are required during
which you used VIEs. The schedule should present major line items, such as revenue and
cost of goods/services, and subtotals and disaggregated intercompany amounts, such as
separate line items for intercompany receivables and investment in subsidiary. The
schedule should also disaggregate the parent company, the VIEs and its consolidated
subsidiaries, the WFOEs that were the primary beneficiary of the VIEs, and an
aggregation of other entities that are consolidated. The objective of this disclosure is to
allow an investor to evaluate the nature of assets held by, and the operations of, entities
apart from the VIE, as well as the nature and amounts associated with intercompany
transactions. Any intercompany amounts should be presented on a gross basis and when
necessary, additional disclosure about such amounts should be included in order to make
the information presented not misleading.
Risk Factors, page 9
12.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to highlight separately the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of the securities you are registering.  Also,
given recent statements by the Chinese government indicating an intent to exert more
oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers, acknowledge the risk that any such action could significantly limit
or completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.

 FirstName LastNameAlfred P.  Poor
 Comapany NameIdeanomics, Inc.
 October 20, 2022 Page 5
 FirstName LastName
Alfred P.  Poor
Ideanomics, Inc.
October 20, 2022
Page 5
13.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your offering and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.
Business
Corporate Structure, page 56
14.Please reconcile the discussion of your organizational structure with the list of subsidiaries
in Exhibit 21.  We note that your disclosure states there are 54 subsidiaries in the
organizational structure, while the exhibit lists 61.
General
15.Please state whether you have one or more directors, officers or members of senior
management located in the PRC/Hong Kong, and if so, identify the relevant individual
and include a separate “Enforceability” section, consistent with Item 101(g) of Regulation
S-K, and a risk factor addressing the challenges of bringing actions and enforcing
judgments/liabilities against such individuals.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Alyssa Wall at 202-551-8106 or Jennifer López Molina at 202-551-3792.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
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IDEANOMICS,
INC.

55 Broadway, 19th Floor

New York, NY 10006

July 17, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Mr. Matthew Derby & Ms. Jan Woo

 Re: Ideanomics,
Inc.

Registration Statement
on Form S-3

File Number 333-239371

REQUEST FOR ACCELERATION
OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness
of the Company’s Registration Statement on Form S-3, File Number 333-239371, so that it will be declared effective on Tuesday
July 21, 2020 at 12:00 p.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company
acknowledges that:

    •
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    •
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •
    the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please
contact our legal counsel, William N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

    Very truly yours,

    Ideanomics, Inc.

    By:

    /s/ Alfred Poor

    Name:

    Alfred Poor

    Title:

    Chief Executive Officer

CORRESP
1
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Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

July 9, 2020

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Matthew Derby

Re: Ideanomics, Inc.

Form S-3 Registration Statement Filed June 23, 2020

File No. 333-239371

Dear Mr. Derby:

On behalf of Ideanomics, Inc., a Nevada corporation (the “Company”),
we submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by telephone on July 7, 2020 (the “Comment Letter”) with respect to the Company’s
above referenced S-3.

For the convenience of the Staff, the numbering of the paragraphs
below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated into this response
letter for convenience in italicized type and which is followed by the Company’s response.

Form S-3

1. We understand that the Form S-3 Registration
Statement which became effective on March 30, 2020 was allocated primarily to an equity line of credit. Will the above-referenced
Form S-3 Registration Statement also be allocated by Ideanomics to establish an equity line of credit?

Ideanomics did previously utilize an equity line of credit but
at present Ideanomics has no agreement or specific method of sale through the Form S-3 with respect to its securities currently
in place. There are a number of different ways in which our securities may be sold under the Form S-3. We will disclose in each
prospectus supplement the necessary details regarding the sales to be made and the plan of distribution for the securities in question
under that prospectus supplement. Ideanomics is seeking to go effective with this Form S-3 in order for the Company to be prepared
to raise money and access the capital markets to best execute upon its corporate strategies on behalf of the Company’s stockholders.
The Company views this action as good corporate planning intended to assist the company in preserving and increasing shareholder
value.

2. We have noted the recent news of a class action
lawsuit filed against Ideanomics. Has Ideanomics considered adding a risk factor to the Form S-3 regarding this recent lawsuit?

In response to this comment Ideanomics will include a risk
factor in the Form S-3 related to the referenced class action lawsuit in the form set forth below.

We are currently, and may in the
future be, subject to substantial litigation, investigations and proceedings that could cause us to incur significant legal expenses
and result in harm to our business.

On July 19, 2019, a purported class action,
captioned Jose Pinto Claro Da Fonseca Miranda v. Ideanomics, Inc., was filed in the United States District Court for the Southern
District of New York against the Company and certain of its current and former officers and directors.   The Amended
Complaint alleges violations of Section 10(b) and 20(a) of the Securities Exchange Act of 1934.  Among other things, the Amended
Complaint alleges purported misstatements made by the Company in 2017 and 2018.  The Company and the other defendants filed
a motion to dismiss that is currently pending before the Court.

On June 28, 2020, a purported securities
class action, captioned Megan Lundy v. Ideanomics was filed in the United State District Court for the Southern District of New
York against the Company and certain current officers and directors of the Company.   Additionally, on July 7, 2020,
a purported securities class action captioned Andrew Kim v. Ideanomics, et al, was filed in the Southern District of New York against
the Company and certain current officers and directors of the Company.  Both cases allege violations of Section 10(b) and
20(a) of the Securities Exchange Act of 1934 arising from certain purported misstatements by the Company beginning in March 2020
regarding its MEG division.  Both complaints have yet to be served on the Company.

While the Company believes that these lawsuits
are without merit and plans to vigorously defend itself against these claims, there can be no assurance that the Company will prevail
in the lawsuits. The Company cannot currently estimate the possible loss or range of losses, if any, that it may experience in
connection with these litigations.

We are exposed to potential liabilities and reputational risk
associated with litigation, regulatory proceedings and government enforcement actions. In addition, we are obligated to indemnify
and advance expenses to certain individuals involved in certain of these proceedings. Further, volatility in our stock price may
also make us vulnerable to future class action litigation.  Any adverse judgment in or
settlement of any pending or any future litigation could result in payments, fines and penalties that could adversely affect our
business, results of operations and financial condition. Regardless of the merits of the claims and the outcome, legal proceedings
have resulted in, and may continue to result in, significant legal fees and expenses, diversion of management’s time and
other resources, and adverse publicity. Such proceedings could also adversely affect our business, results of operations and financial
condition

Should you have any further questions or comments regarding
the captioned filings and/or this letter, please direct them to me at (212) 206-1216 or William N. Haddad, Esq. of Venable LLP,
counsel to the Company at (212) 503-9812.

Very truly yours,

    /s/ Alfred Poor

    Alfred Poor

    Chief Executive Officer

 cc: William N. Haddad, Esq., Venable LLP

CORRESP
1
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IDEANOMICS,
INC.

55 Broadway, 19th Floor

New York, NY 10006

March 26, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 Re: Ideanomics,
Inc.

Registration
Statement on Form S-3

Filed
March 18. 2020

File
Number 333-237251

REQUEST
FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness
of the Company’s Registration Statement on Form S-3, File Number 333-237251, so that it will be declared effective on Monday
March 30, 2020 at 9:00 a.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company
acknowledges that:

 • should
the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 • the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 • the
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please contact our legal counsel, William
N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

    Very truly yours,

    Ideanomics, Inc.

    By:
    /s/ Alfred Poor

    Name:
    Alfred Poor

    Title:
    Chief Executive Officer

March 26, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Registration Statement on Form S-3
Filed March 18, 2020
File No. 333-237251
Dear Mr. Poor:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Kathleen Krebs, Special Counsel, at 202-551-3350 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

February 18, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Form 10-K for the Year Ended December 31, 2018
Filed April 1, 2019
Amendment No. 1 to Form 10-Q for the Quarter Ended September 30, 2019
Filed February 14, 2020
File No. 001-35561
Dear Mr. Poor:
            We have completed our review of your filings.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William N. Haddad

CORRESP
1
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IDEANOMICS,
INC.

55 Broadway, 19th Floor

New York, NY 10006

February 13, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

    Re:
    Ideanomics, Inc.

Registration Statement on Form S-1

File Number 333-224382

REQUEST FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness
of the Company’s Registration Statement on Form S-1, File Number 333-224382, so that it will be declared effective on Thursday
February 13, 2020 at 4:00 p.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company
acknowledges that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •

    the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact our legal counsel, William
N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

    Very truly yours,

    Ideanomics, Inc.

    By:

    /s/ Alfred Poor

    Name:

    Alfred Poor

    Title:

    Chief Executive Officer

CORRESP
1
filename1.htm

Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

February 12, 2020

U. S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn Jacobson

Robert Littlepage

Celeste Murphy

Paul Fischer

Re: Ideanomics, Inc.

Registration Statement on Form S-1/A

Filed on December 31, 2019

File No. 333-224382

Dear Mr. Littlepage and Ms. Jacobson:

On behalf of Ideanomics, Inc., a Nevada corporation (the “Company”),
we submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter on February 10, 2020 (the “Comment Letter”) with respect to the
Company’s

above referenced Forms.

For the convenience of the Staff, the numbering of the paragraphs
below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated into this response
letter for convenience in italicized type and which is followed by the Company’s response. In the

responses below, page number references are to the Registration
Statement.

Registration Statement on Form S-1 Amendment No. 5 filed
February 5, 2020

Issuance of common stock for True-Up related to purchase
of the Delaware Board of Trade, page 9

1. Please disclose the number of shares that you may be
required to issue in the event your common stock trades at its current price on the next lock-up date in April, 2020 pursuant
to the terms of the True-Up provisions of the second securities purchase agreement with the Delaware Board of Trade
(DBOT).

The Company has updated the Recent Developments section on page
9 of the Form S-1/A to include additional disclosure pursuant to the terms for the April 2020 True-Up.

Recent Developments

Impairment Charge on the Company's holdings of Cryptocurrencies,
page 9

2. We note in your response to comment 2 that "the
Company has converted a portion of its holdings of GTB into the more widely traded and liquid Bitcoin (BTC) and Ethereum
(ETH)". In light of your holdings of BTC and ETH, please explain to us the basis for your conclusion that the Company's
holdings of cryptocurrency have a de minimis value.

By way of introduction. The Company’s holdings of cryptocurrency
are reported as holdings of GTB, Bitcoin (BTC) and Ethereum (ETH) in the Company’s account held at the AsiaEDX Exchange.
However, as the Company has disclosed on page F-47 of its S-1/A filing dated February 5, 2020 the holdings of BTC and ETH represent
GTB denominated in Bitcoin & Ethereum and as such do not represent a direct holding of BTC & ETH. Because
the Company does not have a direct holding in Bitcoin and Ethereum, changes in the value of the Company’s Bitcoin & Ethereum
are driven by changes in the GTB price and not the prices for Bitcoin & Ethereum.

Furthermore, on page F-46 of the February 5, 2020 S-1/A filing
the Company has included the following disclosure… “To date the company has not been able to convert any of its crypto
currency holdings to fiat. The Asia EDX exchange has indicated that it continues work towards providing exchangeability for coins
held on the exchange into fiat. Management is unable to give any assurance as to when, if ever, the Asia EDX exchange will permit
conversion of the company’s crypto currency holdings into fiat”

The Company concluded that its holdings of BTC and ETH should
be valued at a de minimis amount because there is no assurance that these holdings can ever be converted to fiat and the underlying
driver of the value of its holdings of BTC & ETH is the price of GTB and not the prices for BTC & ETH.

In response to Staff comments made subsequent to a conference
call on February 11, 2020 between the Company and the Staff, the Company has removed all references to Bitcoin (BTC) and Ethereum
(ETC) in its S-1A filing dated 2-12-2020

Note 16. Earnings/ Loss per Common Share, page F-61

3. Disclose the additional securities issuable pursuant
to contingent stock agreements (including but not limited to the DBOT security agreements with true-up provisions) that could
potentially dilute basic EPS in the future that were not included in the computation of diluted EPS because to do so would have
been antidilutive for the period(s) presented. Refer to ASC 260-10-50-1(c).

The Company has updated its disclosure on page F-61 to include
the additional securities issuable pursuant to contingent stock agreements that could potentially dilute basic EPS in the future
that were not included in the computation of diluted EPS. The DBOT true-up is the only contingent stock agreement that the Company
is party to.

Very truly yours,

/s/ Alfred Poor

Chief Executive Officer

cc: William N. Haddad, Esq., Venable LLP

February 10, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Registration Statement on Form S-1
Filed February 5, 2020
File No. 333-224382
Dear Mr. Poor:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1 Amendment No. 5 filed February 5, 2020
Issuance of common stock for True-Up related to purchase of the Delaware Board of Trade, page
9
1.Please disclose the number of shares that you may be required to issue in the event your
common stock trades at its current price on the next lock-up date in April, 2020 pursuant
to the terms of the True-Up provisions of the second securities purchase agreement with
the Delaware Board of Trade (DBOT).
Recent Developments
Impairment Charge on the Company's holdings of Cryptocurrencies, page 9
2.We note in your response to comment 2 that "the Company has converted a portion of its
holdings of GTB into the more widely traded and liquid Bitcoin (BTC) and Ethereum

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 February 10, 2020 Page 2
 FirstName LastName
Alfred  Poor
Ideanomics, Inc.
February 10, 2020
Page 2
(ETH)".  In light of your holdings of BTC and ETH, please explain to us the basis for your
conclusion that the Company's holdings of cryptocurrency have a de minimis value.
Note 16. Earnings/ Loss per Common Share, page F-61
3.Disclose the additional securities issuable pursuant to contingent stock agreements
(including but not limited to the DBOT security agreements with true-up provisions) that
could potentially dilute basic EPS in the future that were not included in the computation
of diluted EPS because to do so would have been antidilutive for the period(s) presented.
Refer to ASC 260-10-50-1(c).
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or
Robert Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact William Mastrianna,
Attorney-Adviser, at (202) 551-3778 or Celeste Murphy, Legal Branch Chief, at (202) 551-3257
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William N. Haddad

CORRESP
1
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Ideanomics, Inc.

55 Broadway, 19th
Floor

New York, NY 10006

February 5, 2020

U. S. Securities and Exchange Commission

Division of Corporate
Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn
Jacobson

Robert Littlepage

Celeste Murphy

Paul Fischer

Re: Ideanomics,
Inc.

Registration Statement
on Form S-1/A

Filed on December
31, 2019

File No. 333-224382

Dear Mr. Littlepage
and Ms. Jacobson:

On behalf of Ideanomics,
Inc., a Nevada corporation (the “Company”), we submit this letter in response to comments received from the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter on January 27, 2020
(the “Comment Letter”) with respect to the Company’s above referenced Forms.

For the convenience
of the Staff, the numbering of the paragraphs below corresponds to the numbering of the comments in the Comment Letter, the text
of which we have incorporated into this response letter for convenience in italicized type and which is followed by the Company’s
response. In the responses below, page number references are to the Registration Statement.

Form S-1 filed on December 31, 2019

The Offering, page 10

1. We note your disclosure that approximately 20 million
additional shares will be outstanding after the offering. Please provide further detail as to how these additional shares will
become outstanding.

We have updated the Offering section at page 10 of the S-1/A
to address the Staff’s comment.

Overview, page
37

2. We note your
response to comment 9, the memo accompanying your responses, the revised disclosure on page 37 and elsewhere in your filing. We
understand that through Asia EDX you distributed and traded GTB tokens in exchange for Bitcoin and Ether. In light
of such distribution and trading, the GTB token holders' inability to convert such tokens into fiat, and additionally,
the apparent lack of functional applications on the GTD blockchain, please provide us a detailed analysis and your conclusions
with respect to the

following.

In considering The
Company’s response to the Staff’s comments the following overview of the Company’s activities in blockchain
and related technologies maybe helpful.

The Company has
a stated business goal to identify and deploy blockchain applications where it sees commercially viable opportunities to disrupt
established industries and business processes.  The Company’s investment in Amer and Sun Seven Stars Energy were efforts
to learn about the markets and business processes in the electronic components and oil industries, respectively. Similarly, the
Company’s Digital Asset Management Services Agreement with GT Dollar (GTD) was also part of this type of initiative.
For clarity, in its provision of services under the Digital Asset Management Services Agreement, the Company provided consulting
advice on the deployment of blockchain and Artificial Intelligence (AI) technologies on the GTD blockchain platform. The Company
was not, and is not, involved in the management or operation of the GTD platform.   As referenced
on p. 78 of the Company’s S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain
technology to create and trade digital securities referred to as digital tokens; however, the Company has not commenced
this activity. If and when the Company engages in such activity it anticipates using its FINRA registered Broker Dealer, The Delaware
Board of Trade (DBOT) and its registered Alternative Trading System (ATS) as the platform for distributing and trading digital
securities, subject to having obtained all necessary regulatory approvals and licenses.

Separately,
and unrelated to the blockchain and digital token business objectives discussed above, the Company holds GTB cryptocurrency (GTB).
The Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible,
subject to market conditions.  It is not the Company’s intention in any way to trade the GTB in an attempt
to profit from changes in the market price.  The Company received the GTB simply as payment for content that it sold to GTD
and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement discussed above
and has been making efforts only to convert the GTB to fiat.  In the absence of the AsiaEDX exchange permitting the conversion
of GTB to fiat, the Company has converted a portion of its holdings of GTB into the more widely traded and liquid Bitcoin (BTC)
and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency less subject to volatile price movements.
The Company will update its disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures
contained in the Form S-1/A filed on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC
 & ETH are subject to changes in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Explain to us whether GTB tokens
may be deemed a security. In this regard, we note your disclosure on page 21 that "speculators and investors who seek to
profit from trading and holding GTB currently account for a significant portion of GTB demand." On page F-47, you further
state that "the value of GTB is determined by the value that various market participants place on GTB through their transactions.
GTB holders make or lose money from buying and selling GTB." We also note GTB's trading history which you provided supplementally
and your reference to the four-part Howey test on page 78.

As
stated above, the Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as
quickly as possible, subject to market conditions.  It is not the Company’s intention in any way to trade
the GTB in an attempt to profit from changes in the market price.  The Company received the GTB simply as payment for content
that it sold to GTD and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement
discussed above and has been making efforts only to convert the GTB to fiat. As referenced on p. 78 of the Company’s
S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain technology to create and trade
digital securities referred to as digital tokens; however, the Company has not commenced this activity. The Company will
only commence this activity once a regulatory framework is in place and in compliance with such regulatory framework. In the absence
of the AsiaEDX exchange permitting the conversion of GTB to fiat, the Company has converted a portion of its holdings of GTB into
the more widely traded and liquid Bitcoin (BTC) and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency
less subject to volatile price movements.  The Company will update its disclosures in future Form 10-K and Form 10-Q
filings in a manner similar to those disclosures contained in the Form S-1/A filed on February 5, 2020 in order to clarify that
the value of the Company’s holdings of BTC & ETH are subject to changes in the price ratio of GTB to US$ rather than
the quoted price of BTC & ETH. Based upon the foregoing and the fact that the Company is not acting as a speculator or investor
intending to make or lose money from buying and selling GTB, the Company does not believe that whether the GTB tokens are deemed
a security is relevant.

• Tell us whether your distribution
of GTB tokens through the Asia EDX in exchange for Bitcoin and Ether may be deemed an initial exchange offering subject to SEC
registration.

As explained above, the Company is not
now, nor was it ever in the past, distributing GTB tokens. The Company is a passive holder of GTB, Bitcoin and Ethereum
with the sole objective of converting these holdings to fiat. The Company’s conversion of GTB into Bitcoin and Ethereum
was done solely as an effort to reduce volatility and market risk by converting a portion of the Company’s holdings of GTB
to Bitcoin and Ethereum which are more liquid and normally less volatile in terms of price change. The Company will update its
disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form S-1/A filed
on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject to changes
in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Explain
how you concluded that GTB tokens held for trading may be characterized as intangible assets. Refer us to your basis in the accounting
literature.

As explained above,
the Company does not hold GTB, Bitcoin or Ethereum for the purposes of trading the holdings. The Company is a passive
holder of GTB, Bitcoin and Ethereum with the sole objective of converting these holdings to fiat.

Below is the relevant
extract from the Company’s accounting memo related to its holdings of GTB. The full memo was provided as an Appendix to
the Company’s response on January 15, 2020 to the previous comment letter on the S-1 filing

“Given
that there is limited precedent regarding the classification and measurement of cryptocurrencies and other digital tokens under
current Generally Accepted Accounting Principles (“GAAP”), the Company has determined to account for these tokens
as indefinite-lived intangible assets by reference to the existing International Financial Reporting Standards (“IAS 38”)
and apply analogy to ASC 350, Intangibles—Goodwill and Other until further guidance is issued by the FASB because:

 a. it
                                         is a resource controlled by an entity (that is, the entity has the power to obtain the
                                         economic benefits that the asset will generate and to restrict the access of others to
                                         those benefits) as a result of past events and from which future economic benefits are
                                         expected to flow to the entity;

 b. it
                                         is identifiable, because it can be sold, exchanged or transferred individually;

 c. it
                                         is not cash or a non-monetary asset; and

 d. it
                                         has no physical form.

Therefore,
we recorded GTB tokens at cost and not subject to amortization, but shall be tested for impairment annually and more frequently
if events or changes in circumstances indicate that it is more likely than not that they are impaired. If, at the time of an impairment
test, the carrying amount of an intangible asset exceeds its fair value, an impairment loss in an amount equal to the excess is
recognized in the statement of operations.”

As discussed on
a conference call with the SEC staff on January 29, 2020, the Company has included disclosure regarding the impairment of GTB
tokens in the “Recent Developments” section of the Form S-1/A filed with the SEC on February 5, 2020.

• Compare
for us your total GTB holdings, including those which are denominated in Bitcoin and Ether, to the total GTB circulating supply
based on information available through Asia EDX and GT Dollar.

The Company has
been unable to find information regarding the total GTB circulating supply from any source including Asia EDX and GT Dollar.

•
Explain if and when you will be able to exchange your GTB tokens denominated in Bitcoin and Ether into other digital
currencies. Since your holdings of GTB tokens denominated in Bitcoin and Ether do not constitute direct holdings of such
currencies, please explain to us how the GTB/BTC and GTB/ ETH conversion ratios (per your supplementary materials) were
determined and when and how such denominations may be converted into direct holdings. Further clarify if settlement of the
exchange transaction is the subject of a futures or forward contract.

The AsiaEDX currently
permits holders of cryptocurrencies on the exchange to convert holdings between the various cryptocurrencies traded on the exchange.
The AsiaEDX exchange currently does not permit the conversion of cryptocurrencies into fiat. The Company’s disclosure in
its most recently filed S-1/A on December 31, 2019 includes disclosures relating to the inability of the Company to convert its
holdings of GTB, BTC and ETH into fiat – see the Overview on page 37 and Note 19, “Concentration, Credit and Other
Risks” subsection (f) “Digital Currency Risks” on page F-64.

Conversions of cryptocurrencies
quoted on the AsiaEDX platform are executed at the rates quoted on the platform at the time of exchange / conversion. The company
has no control over the quoted rates. The settlement of exchange transactions does not require nor result in a futures or forward
contract.

The Company will
update its disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form
S-1/A filed on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject
to changes in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Tell us
if you may be deemed a broker/dealer of GTB tokens or a money services business (i.e., an administrator of the GTD blockchain)
subject to securities and commodities, money services and transmitter laws which you referenced on pages 78-79 of your filing.
Please provide us a detailed evaluation of your capacity to distribute and trade GTB tokens in this regard.

As stated above,
the Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible,
subject to market conditions.  It is not the Company’s intention in any way to trade the GTB in an attempt
to profit from changes in the market price.  The Company received the GTB simply as payment for content that it sold to GTD
and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement discussed above
and has been making efforts only to convert the GTB to fiat.  In the absence of the AsiaEDX exchange permitting the conversion
of GTB to fiat, the Company has converted a portion of its holdings of GTB into the more widely traded and liquid
Bitcoin (BTC) and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency less subject to volatile price
movements.  The Company has no intention at all nor does it possess any capacity at all distribute and trade tokens. Based
upon the foregoing, the Company does not believe that it could be deemed in any way a broker/dealer of GTB tokens or a money services
business subject to relevant law. As referenced on p. 78 of the Company’s S-1/A filed on December 31, 2019, the Company
believes that there is potential to use blockchain technology to create and trade digital securities referred to as digital tokens;
however, the Company has not commenced this activity. If, in the future, the Company decides to commence this activity
it will only do so once all the necessary regulatory approvals and licenses have been obtained. Subject to any regulations then
in place, the Company anticipates using its FINRA registered Broker Dealer, The Delaware Board of Trade (DBOT) and its registered
Alternative Trading System (ATS) as the platform for distributing and trading digital securities and tokens in the event that
the Company is able to create any digital securities.

Note 1. Nature of Operations and Summary of Significant
Accounting Policies

Digital Currency, page F-47

3. We note your response to comment 6. Please expand your
disclosure to identify the applications that are currently functional on the GTD block chain and the extent to which GTB token
holders have utilized their token holdings to access such applications. Clarify your disclosure to state whether Asia EDX allows
such holders to acces

CORRESP
1
filename1.htm

Ideanomics, Inc.

55 Broadway, 19th
Floor

New York, NY 10006

February 5, 2020

U. S. Securities and
Exchange Commission

Division of Corporate
Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn
Jacobson

Robert Littlepage

Paul Fischer

Celeste Murphy

Re: Ideanomics,
Inc.

Form 10-K for the
Year Ended December 31, 2018 Filed April 1, 2019

Form 10-Q for the
Quarter Ended September 30, 2019 Filed November 14, 2019

Response Letter
Dated January 9, 2020

File No. 001-35561

Dear Mr. Littlepage
and Ms. Jacobson:

On behalf of Ideanomics, Inc., a Nevada
corporation (the “Company”), we submit this letter in response to comments received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) by letter on January 29, 2020 (the “Comment Letter”)
with respect to the Company’s above referenced Forms.

For the convenience of the Staff, the
numbering of the paragraphs below corresponds to the numbering of the comments in the Comment Letter, the text of which we have
incorporated into this response letter for convenience in italicized type and which is followed by the Company’s response.
In the responses below, page number references are to the Registration Statement.

Form 10-Q for the Quarter Ended September
30, 2019

Note 1. Nature of Operations and Summary
of Significant Accounting Policies

Digital Currency, page 10

1. Please expand your disclosure to
identify the applications that are currently functional on the GTD block chain and the extent to which GTB token holders have
utilized their token holdings to access such applications. Clarify your disclosure to state whether Asia EDX allows such holders
to access and use their GTB tokens in exchange for goods and services sold by participating merchants, absent any ability to convert
such tokens into fiat.

In response
to this comment the Company has expanded its disclosure in the Form S-1/A filed on February 5, 2020 to include reference to GTB
being used to pay for purchases at participating merchants. The Company will include such disclosure in future filings on Form
10-Q and 10-K. The updated disclosure is included on page F-47 — Digital Currency.

Note 5. Acquisitions and Divestitures

(h) Amer Global Technology Limited
("Amer"), page 17

2. It appears that Amer may be deemed
a discontinued operation as your ownership interest was diluted to 0% as of August 31, 2019 and you no longer are involved in
the consumer electronics trading business. Accordingly, please revise your presentation and related disclosures as appropriate.
Refer to ASC 205-10-15-2, ASC 205-20-451B(b), and ASC 205-20-50-5

We assume that your reference to 0% in
the above paragraph was intended to reference the Company’s holding in Amer of 10%

At the time of disposal of the Company’s
majority ownership interest in Amer consideration was given as to whether Amer should be considered a discontinued operation.
In accordance with the guidance, the Company believes that Amer should not be considered a discontinued operation as the disposal
does not represent a strategic shift away from the Company’s business strategy of seeking opportunities to deploy blockchain
and AI technologies to disrupt established industries and business processes. The Company has been consistent in its disclosure
that Amer was purchased as a means of learning about the consumer electronics industry with the goal of identifying opportunities
to deploy blockchain in a disruptive manner. The Company disposed of Amer because it believes that it had extracted most of the
learnings to be had through majority ownership. Please see page 34 of the Company’s 10-Q filing for the period ended September
30, 2018 and page 3 of the 10-K filing for the Year Ended December 31, 2018 for discussion of the rationale for the Company’s
investment in Amer.

Overview, page 32

3. We understand from your disclosure
elsewhere in your filing that through Asia EDX you distributed and traded GTB tokens in exchange for Bitcoin and Ether. In light
of such distribution and trading, the GTB token holders' inability to convert such tokens into fiat, and additionally, the apparent
lack of functional applications on the GTD blockchain, please provide us a detailed analysis and your conclusions with respect
to the following:

In considering The Company’s response
to the Staff’s comments the following overview of the Company’s activities in blockchain and related technologies
maybe helpful.

The Company has a stated business goal
to identify and deploy blockchain applications where it sees commercially viable opportunities to disrupt established industries
and business processes.  The Company’s investment in Amer and Sun Seven Stars Energy were efforts to learn about the
markets and business processes in the electronic components and oil industries, respectively. Similarly, the Company’s Digital
Asset Management Services Agreement with GT Dollar (GTD) was also part of this type of initiative.  For clarity, in its provision
of services under the Digital Asset Management Services Agreement, the Company provided consulting advice on the deployment of
blockchain and Artificial Intelligence (AI) technologies on the GTD blockchain platform. The Company was not, and
is not, involved in the management or operation of the GTD platform.   As referenced on p. 78 of the Company’s
S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain technology to create and trade
digital securities referred to as digital tokens; however, the Company has not commenced this activity. If and when the
Company engages in such activity it anticipates using its FINRA registered Broker Dealer, The Delaware Board of Trade (DBOT) and
its registered Alternative Trading System (ATS) as the platform for distributing and trading digital securities, subject to having
obtained all necessary regulatory approvals and licenses.

Separately,
and unrelated to the blockchain and digital token business objectives discussed above, the Company holds GTB cryptocurrency (GTB).
The Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible,
subject to market conditions.  It is not the Company’s intention in any way to trade the GTB in an attempt
to profit from changes in the market price.  The Company received the GTB simply as payment for content that it sold to GTD
and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement discussed above
and has been making efforts only to convert the GTB to fiat.  In the absence of the AsiaEDX exchange permitting the conversion
of GTB to fiat, the Company has converted a portion of its holdings of GTB into the more widely traded and liquid Bitcoin (BTC)
and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency less subject to volatile price movements.
The Company will update its disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures
contained in the Form S-1/A filed on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC
 & ETH are subject to changes in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Explain to us whether GTB tokens
may be deemed a security. In this regard, we note your disclosure on page 21 that "speculators and investors who seek to
profit from trading and holding GTB currently account for a significant portion of GTB demand." On page F-47, you further
state that "the value of GTB is determined by the value that various market participants place on GTB through their transactions.
GTB holders make or lose money from buying and selling GTB." We also note GTB's trading history which you provided supplementally
and your reference to the four-part Howey test on page 78.

As
stated above, the Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as
quickly as possible, subject to market conditions.  It is not the Company’s intention in any way to trade
the GTB in an attempt to profit from changes in the market price.  The Company received the GTB simply as payment for content
that it sold to GTD and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement
discussed above and has been making efforts only to convert the GTB to fiat. As referenced on p. 78 of the Company’s
S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain technology to create and trade
digital securities referred to as digital tokens; however, the Company has not commenced this activity. The Company will
only commence this activity once a regulatory framework is in place and in compliance with such regulatory framework. In the absence
of the AsiaEDX exchange permitting the conversion of GTB to fiat, the Company has converted a portion of its holdings of GTB into
the more widely traded and liquid Bitcoin (BTC) and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency
less subject to volatile price movements.  The Company will update its disclosures in future Form 10-K and Form 10-Q
filings in a manner similar to those disclosures contained in the Form S-1/A filed on February 5, 2020 in order to clarify that
the value of the Company’s holdings of BTC & ETH are subject to changes in the price ratio of GTB to US$ rather than
the quoted price of BTC & ETH. Based upon the foregoing and the fact that the Company is not acting as a speculator or investor
intending to make or lose money from buying and selling GTB, the Company does not believe that whether the GTB tokens are deemed
a security is relevant.

• Tell us whether your distribution
of GTB tokens through the Asia EDX in exchange for Bitcoin and Ether may be deemed an initial exchange offering subject to SEC
registration.

As explained above, the Company is not
now, nor was it ever in the past, distributing GTB tokens. The Company is a passive holder of GTB, Bitcoin and Ethereum
with the sole objective of converting these holdings to fiat. The Company’s conversion of GTB into Bitcoin and Ethereum
was done solely as an effort to reduce volatility and market risk by converting a portion of the Company’s holdings of GTB
to Bitcoin and Ethereum which are more liquid and normally less volatile in terms of price change. The Company will update its
disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form S-1/A filed
on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject to changes
in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Explain how you concluded that
GTB tokens held for trading may be characterized as intangible assets. Refer us to your basis in the accounting literature.

As explained above, the Company does not
hold GTB, Bitcoin or Ethereum for the purposes of trading the holdings. The Company is a passive holder of GTB,
Bitcoin and Ethereum with the sole objective of converting these holdings to fiat.

Below is the relevant extract from the
Company’s accounting memo related to its holdings of GTB. The full memo was provided as an Appendix to the Company’s
response on January 15, 2020 to the previous comment letter on the S-1 filing

“Given that there
is limited precedent regarding the classification and measurement of cryptocurrencies and other digital tokens under current Generally
Accepted Accounting Principles (“GAAP”), the Company has determined to account for these tokens as indefinite-lived
intangible assets by reference to the existing International Financial Reporting Standards (“IAS 38”) and apply analogy
to ASC 350, Intangibles—Goodwill and Other until further guidance is issued by the FASB because:

 a. it
                                         is a resource controlled by an entity (that is, the entity has the power to obtain the
                                         economic benefits that the asset will generate and to restrict the access of others to
                                         those benefits) as a result of past events and from which future economic benefits are
                                         expected to flow to the entity;

 b. it
                                         is identifiable, because it can be sold, exchanged or transferred individually;

 c. it
                                         is not cash or a non-monetary asset; and

 d. it
                                         has no physical form.”

Therefore, we recorded GTB tokens at cost and not subject to
amortization, but shall be tested for impairment annually and more frequently if events or changes in circumstances indicate that
it is more likely than not that they are impaired. If, at the time of an impairment test, the carrying amount of an intangible
asset exceeds its fair value, an impairment loss in an amount equal to the excess is recognized in the statement of operations.”

• Compare for us your total GTB
holdings, including those which are denominated in Bitcoin and Ether, to the total GTB circulating supply based on information
available through Asia EDX and GT Dollar.

The Company has been unable to find information
regarding the total GTB circulating supply from any source including Asia EDX and GT Dollar.

• Explain if and when you will
be able to exchange your GTB tokens denominated in Bitcoin and Ether into other digital currencies. Since your holdings of GTB
tokens denominated in Bitcoin and Ether do not constitute direct holdings of such currencies, please explain to us how the GTB/BTC
and GTB/ ETH conversion ratios (per your supplementary materials) were determined and when and how such denominations may be converted
into direct holdings. Further clarify if settlement of the exchange transaction is the subject of a futures or forward contract.

The AsiaEDX currently permits holders
of cryptocurrencies on the exchange to convert holdings between the various cryptocurrencies traded on the exchange. The AsiaEDX
exchange currently does not permit the conversion of cryptocurrencies into fiat. The Company’s disclosure in its most recently
filed S-1/A on December 31, 2019 includes disclosures relating to the inability of the Company to convert its holdings of GTB,
BTC and ETH into fiat – see the Overview on page 37 and Note 19, “Concentration, Credit and Other Risks” subsection
(f) “Digital Currency Risks” on page F-64.

Conversions of cryptocurrencies quoted
on the AsiaEDX platform are executed at the rates quoted on the platform at the time of exchange / conversion. The company has
no control over the quoted rates. The settlement of exchange transactions does not require nor result in a futures or forward
contract.

The Company will update its disclosures
in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form S-1/A filed on February
5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject to changes in the price
ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• Tell us if you may be deemed
a broker/dealer of GTB tokens or a money services business (i.e., an administrator of the GTD blockchain) subject to securities
and commodities, money services and transmitter laws which you referenced on pages 78-79 of your filing. Please provide us a detailed
evaluation of your capacity to distribute and trade GTB tokens in this regard.

As stated above, the Company is a passive
holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible, subject to market conditions.
It is not the Company’s intention in any way to trade the GTB in an attempt to profit from changes in the
market price.  The Company received the GTB simply as payment for c

January 29, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Form 10-K for the Year Ended December 31, 2018
Filed April 1, 2019
Form 10-Q for the Quarter Ended September 30, 2019
Filed November 14, 2019
Response Letter Dated January 9, 2020
File No. 001-35561
Dear Mr. Poor:
            We have reviewed your January 9, 2020 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
October 16, 2019 letter.
Form 10-Q for the Quarter Ended September 30, 2019
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page 10
1.Please expand your disclosure to identify the applications that are currently functional on
the GTD block chain and the extent to which GTB token holders have utilized their token
holdings to access such applications.  Clarify your disclosure to state whether Asia EDX
allows such holders to access and use their GTB tokens in exchange for goods and
services sold by participating merchants, absent any ability to convert such tokens into
fiat.

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 29, 2020 Page 2
 FirstName LastNameAlfred  Poor
Ideanomics, Inc.
January 29, 2020
Page 2
Note 5. Acquisitions and Divestitures
(h) Amer Global Technology Limited ("Amer"), page 17
2.It appears that Amer may be deemed a discontinued operation as your ownership interest
was diluted to 0% as of August 31, 2019 and you no longer are involved in the consumer
electronics trading business.  Accordingly, please revise your presentation and related
disclosures as appropriate.  Refer to ASC 205-10-15-2, ASC 205-20-451B(b), and ASC
205-20-50-5.
Overview, page 32
3.We understand from your disclosure elsewhere in your filing that through Asia EDX you
distributed and traded GTB tokens in exchange for Bitcoin and Ether.  In light of such
distribution and trading, the GTB token holders' inability to convert such tokens into fiat,
and additionally, the apparent lack of functional applications on the GTD blockchain,
please provide us a detailed analysis and your conclusions with respect to the following:
•Explain to us whether GTB tokens may be deemed a security.  In this regard, we note
your disclosure on page 44 that "speculators and investors who seek to profit from
trading and holding GTB currently account for a significant portion of GTB
demand."  On page 11, you further state that "the value of GTB is determined by the
value that various market participants place on GTB through their transactions. GTB
holders make or lose money from buying and selling GTB."  We also note GTB's
trading history which you provided supplementally and your reference to the four-
part Howey test on page 78 of the Form S-1.
•Tell us whether your distribution of GTB tokens through the Asia EDX in exchange
for Bitcoin and Ether may be deemed an initial exchange offering subject to SEC
registration.
•Explain how you concluded that GTB tokens held for trading may be characterized as
intangible assets.  Refer us to your basis in the accounting literature.
•Compare for us your total GTB holdings, including those which are denominated in
Bitcoin and Ether, to the total GTB circulating supply based on information available
through Asia EDX and GT Dollar.
•Explain if and when you will be able to exchange your GTB tokens denominated in
Bitcoin and Ether into other digital currencies.  Since your holdings of GTB tokens
denominated in Bitcoin and Ether do not constitute direct holdings of such currencies,
please explain to us how the GTB/BTC and GTB/ ETH conversion ratios (per your
supplementary materials) were determined and when and how such denominations
may be converted into direct holdings.  Further clarify if settlement of the exchange
transaction is the subject of a futures or forward contract.
•Tell us if you may be deemed a broker/dealer of GTB tokens or a money services
business (i.e., an administrator of the GTD blockchain) subject to securities and
commodities, money services and transmitter laws which you referenced on pages
78-79 of your S-1 filing.  Please provide us a detailed evaluation of your capacity to
distribute and trade GTB tokens in this regard.

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 29, 2020 Page 3
 FirstName LastName
Alfred  Poor
Ideanomics, Inc.
January 29, 2020
Page 3
            You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or
Robert Littlepage, Accountant Branch Chief if you have questions regarding comments on the
financial statements and related matters.  Please contact William Mastrianna, Staff Attorney at
(202) 551-3778 or Celeste Murphy, Legal Branch Chief at (202) 551-3257 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William N. Haddad

January 27, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Registration Statement on Form S-1/A
Filed on December 31, 2019
File No. 333-224382
Dear Mr. Poor:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 9, 2019 letter.
Form S-1 filed December 31, 2019
The Offering, page 10
1.We note your disclosure that approximately 20 million additional shares will be
outstanding after the offering.  Please provide further detail as to how these additional
shares will become outstanding.
Overview, page 37
2.We note your response to comment 9, the memo accompanying your responses, the
revised disclosure on page 37 and elsewhere in your filing.  We understand that through
Asia EDX you distributed and traded GTB tokens in exchange for Bitcoin and Ether.  In
light of such distribution and trading, the GTB token holders' inability to convert such

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 27, 2020 Page 2
 FirstName LastNameAlfred  Poor
Ideanomics, Inc.
January 27, 2020
Page 2
tokens into fiat, and additionally, the apparent lack of functional applications on the GTD
blockchain, please provide us a detailed analysis and your conclusions with respect to the
following.
•Explain to us whether GTB tokens may be deemed a security.  In this regard, we note
your disclosure on page 21 that "speculators and investors who seek to profit from
trading and holding GTB currently account for a significant portion of GTB
demand."  On page F-47, you further state that "the value of GTB is determined by
the value that various market participants place on GTB through their transactions.
GTB holders make or lose money from buying and selling GTB."  We also note
GTB's trading history which you provided supplementally and your reference to the
four-part Howey test on page 78.
•Tell us whether your distribution of GTB tokens through the Asia EDX in exchange
for Bitcoin and Ether may be deemed an initial exchange offering subject to SEC
registration.
•Explain how you concluded that GTB tokens held for trading may be characterized as
intangible assets.  Refer us to your basis in the accounting literature.
•Compare for us your total GTB holdings, including those which are denominated in
Bitcoin and Ether, to the total GTB circulating supply based on information available
through Asia EDX and GT Dollar.
•Explain if and when you will be able to exchange your GTB tokens denominated in
Bitcoin and Ether into other digital currencies.  Since your holdings of GTB tokens
denominated in Bitcoin and Ether do not constitute direct holdings of such currencies,
please explain to us how the GTB/BTC and GTB/ ETH conversion ratios (per your
supplementary materials) were determined and when and how such denominations
may be converted into direct holdings.  Further clarify if settlement of the exchange
transaction is the subject of a futures or forward contract.
•Tell us if you may be deemed a broker/dealer of GTB tokens or a money services
business (i.e., an administrator of the GTD blockchain) subject to securities and
commodities, money services and transmitter laws which you referenced on pages
78-79 of your filing.  Please provide us a detailed evaluation of your capacity to
distribute and trade GTB tokens in this regard.
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page F-47
3.We note your response to comment 6.  Please expand your disclosure to identify the
applications that are currently functional on the GTD block chain and the extent to which
GTB token holders have utilized their token holdings to access such applications.  Clarify
your disclosure to state whether Asia EDX allows such holders to access and use their
GTB tokens in exchange for goods and services sold by participating merchants, absent
any ability to convert such tokens into fiat.

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 27, 2020 Page 3
 FirstName LastName
Alfred  Poor
Ideanomics, Inc.
January 27, 2020
Page 3

Note 6. Accounts Receivable, page F-51
4.We note that you sold your Amer subsidiary which had accounted for a significant portion
of your uncollected long-term receivables through August 31, 2019.  Please tell us your
consideration of the Amer subsidiary as a discontinued operation pursuant to ASC 205-
20-45-1(B)(b).  In this regard, we note that your ongoing operations appear to constitute a
significant strategic shift from your former trading business in 2018.
General
5.We note your Form 8-K filing on January 10, 2020 discussing a letter from Nasdaq's
listing qualifications staff regarding the company's compliance with certain listing
standards.  Please prominently disclose and discuss these developments in your
prospectus.
            You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact William Mastrianna,
Staff Attorney at (202) 551-3778 or Celeste Murphy, Legal Branch Chief at (202) 551-3257 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William N. Haddad

CORRESP
1
filename1.htm

Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

January 15, 2020

U. S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn Jacobson

Robert Littlepage

Celeste Murphy

Paul Fischer

Re: Ideanomics, Inc.

Registration Statement on Form S-1/A

File No. 333-224382

Dear Mr. Fischer and Ms. Murphy:

On behalf of Ideanomics, Inc., a Nevada corporation (the “Company”),
we submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter on August 9, 2019 (the “Comment Letter”) with respect to the Company’s

above referenced Forms.

For the convenience of the Staff, the numbering of the paragraphs
below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated into this response
letter for convenience in italicized type and which is followed by the Company’s response. In the

responses below, page number references are to the Registration
Statement.

Registration Statement on Form S-1/A, filed on August 2,
2019

We are subject to risks related to holding cryptocurrencies
and accepting cryptocurrencies as a form of payment., page 21

 1. Please revise your risk factor to address other potential
risks related to holding the GTB cryptocurrency you received in March, 2019, including risks related to the storage or custody
of the private key(s) granting access to the digital assets, such as the threat of a cybersecurity breach, as well as potential
risks created by events on the underlying blockchain, such as "forks" and "airdrops." Please also discuss
either here or in another part of your prospectus your current storage and custodial practices with respect to the GTB cryptocurrency.

The risk factor was updated in our S-1 A 4th Amendment filed
on December 31, 2019 to address the above comments

 2. We note your statement in paragraph two that you "currently expect to hold [y]our GTB unless you need cash to support
your operations, at which time you may determine to convert to fiat currency and U.S. dollars." With a view towards disclosure,
please advise what consideration you gave to the inclusion of risk factor disclosure addressing the possible need to register as
an investment company under the Investment Company Act.

We do not consider it likely that we will need to register as
an investment company. Under Section 3(b)(1) of the 1940 Act, an issuer is not an investment
company if it is primarily engaged, directly or through wholly-owned subsidiaries, in a business other than that of investing,
reinvesting, owning, holding or trading in securities, we believe that Ideanomics meets this criteria. Furthermore, we believe
that we meet the five principal factors set-out in Tonopah Mining Co. for determining an issuer’s "primary
business" under Section 3(b)(2) and that applying these factors supports our position that Ideanomics is not an investment
company. We will continue to monitor our business in the context of the Investment Company Act.

Overview, page 36

 3. In light of your significant holdings of GTB tokens, please describe in your MD&A overview your plan to monetize these
tokens.

The MD&A has been updated at page 37 of the S-1A filed on
December 31, 2019 to address the above comment.

Comparison of Three Months Ended March 31, 2019 and 2018
Selling, general and administrative Expenses, page 42

 4. We note that on February 12, 2019, you entered into separate covenants not to sue with certain individuals. Please disclose
the significant terms of these agreements, including but not limited to payable consideration of $800,000 in the aggregate, and
how you accounted for them in the financial statements. Refer to Exhibits 10.11, 10.12, and 10.13 of the Form 10-Q filed on May
2, 2019 and the Form 8-K filed on February 26, 2019.

The MD&A in the Form 10-Q filing for the period ending September
30, 2019 has been updated to address the above comment and has also been included in the S-1A filed on December 31, 2019 to address
the above comment.

Legal Matters, page 106

 5. We note that Sherman & Howard will pass upon the validity of the shares you are offering pursuant to the registration
statement, however see no Exhibit 5.1 in your Exhibits list.

Please file counsel's opinion as an
exhibit to your filing prior to requesting effectiveness, allowing sufficient time for staff review. Please refer to Item 601(b)(5)(i)
of Regulation SK.

We will file the legal opinion when the
S-1A is ready to go effective, allowing sufficient time for staff review.

Note 1. Nature of Operations and Summary of Significant Accounting
Policies

Digital Currency, page F-47

 6. We note that GTB "is not backed by hard assets
or other financial instruments and does not represent an investment in GTD or a right to access GTD's platform." If so, please
help us reconcile this disclosure with your March 19, 2019 press release which reported that GT Dollar has been underwriting its
tokens with asset-backed collateral, including real estate, airlines, insurance as well as regional bank clearance and acceptance,
to launch consumer loyalty programs for those using GT Dollar when it initially launched." Refer to your press release at
https://www.prnewswire.com/newsreleases/ ideanomics-signs-digital-asset- management-services-agreement-withsingapores-gt-dollar-and-thai-setaku-insurance-
300814769.html.

The press release was describing the GT Dollar (GTD) entity’s
operating model as we understood it. GTB refers to the cryptocurrency that runs on the GTD block chain. Holders of GTB have the
right to access applications that run on the GTD block chain but do not have an ownership interest in GTD or the rights to access
or use its block chain other than for approved applications. For example, the GTD block chain has a payment application that allows
holders of GTB to purchase and pay for goods and services from participating merchants – we understand that some taxi cabs
and coffee shops in Singapore accept payment in GTB – however access to the payment application does not confer any rights
to GTD

Additionally, it does not appear that Asia EDX
Exchange (Https://asiaedx.com) has a functioning website or that it is operational. Please advise
us.

We have been able to interact with the Asia EDX website, however
there does appear to be a number of dead or inoperative links.

 7. We also note per Exhibit 10.14 of the Form 10-Q filed May 2, 2019 that Thai Setaku Insurance is a counterparty to your Service
Agreement with GT Dollar. Please disclose its role and its respective rights and obligations in connection with the subject agreement.

The business plan for GTB included a product (DICA) which can
most easily be described as a form of cash back plan for purchases made with GTB, similar in nature to the ones offered by credit
card companies. The DCIA cash back program would have operated using an investment fund with consumers who used GTB for purchases
getting a periodic dividend, paid in GTB proportionate to their purchases. If the DICA product had been marketed as originally
envisaged the fund underlying the DICA would have been underwritten by Thai Setaku Insurance. The DCIA product has not been marketed
and consequently the services of Setaku Thai Insurance have not been used.

 8. Please tell us and disclose how you adjusted the Black-Scholes option pricing model to value the GT tokens. Also, please
disclose how you determined the surrogate inputs to the model such as the option strike price and the current stock price.

Due to the limited trading history and the existence of a singular
currency exchange platform, the Company determined that GTB tokens contained a lack of marketability. Therefore, the Company used
a Black-Scholes Option Pricing Method (“BSOPM”) that is used to estimate a discount for lack of marketability (“DLOM”)
in connection to the restricted common stock of a public company that must be held (not traded) until a given holding period lapses.
At the end of the holding period, the trading restrictions on the stock lapse and the shares revert to an unrestricted, freely-traded
basis (so called Put Option Model). In the Put Option Model, the key drivers of the DLOM are the stock price volatility ratio and
the holding period term. We calculated the volatility of GTB tokens for the period since inception to April 29, 2019 and estimated
the holding period as 3 years (since the contract’s service period with GTD is 3 years for exclusive marketing services).
The implied DLOM is 61% (Please see Exhibit A). We further considered that we also need to consider the volatility of BTC or ETH.
Therefore, we estimated volatility for both GTB tokens and BTC/ETH is 155% and the implied DLOM is 76%. For the purposes of the
BSOPM, the Company assumed an at the money option with a stock price of $1

 9. Please disclose in greater detail the nature of the GT digital currency. Clarify whether a GTB token as referenced in your
response is the same as a GT token as referenced in your service agreement. Also, disclose whether it is convertible into a fixed
or variable amount of conventional currency and whether you will be able to use it freely in commerce in exchange for goods and
services, both within and away from the GT Dollar platform.

GT digital currency (“GTB”) is a type of digital
asset traded on the Asia EDX exchange. We believe GTB was created as an alternative to fiat currency as a vehicle to transfer value.
GTB is not a fiat currency and is not backed by hard assets or other financial instruments. GTB does not represent an investment
in GT Dollar Pte. Ltd. (“GTD”) or a right to access GTD’s platform. As a result, the value of GTB is determined
by the value that various market participants place on GTB through their transactions.

GTB holders make or lose money from buying and selling GTB;
however, we are not aware of any observable transactions in which GTB has been bought or sold in exchange for cryptocurrencies
or fiat currency. To date, the Asia EDX exchange has not permitted holders of GTB, Bitcoin or Ethereum to convert digital currencies
held in accounts at the Asia EDX exchange for fiat currency. The Company is unable to predict when its GTB will be convertible
into fiat and consequently does not consider GTB to be part of the Company’s liquid resources.

Note 6. Accounts Receivable, page F-51

 10. Considering that most of your receivables exceed 180 days, please tell us why you have experienced significant payment delays
and what amounts you received (if any) subsequent to your first quarter. Tell us whether contract provisions limit your exposure
to credit risk and whether you have an enforceable right to payment. If not, tell us the factors you considered in determining
their collectability apart from oral promises.

The payment delays were related to receivables owed to our Amer
subsidiary which were caused by the banks closing of the accounts held by Amer with that institution. We were assured that the
receivables would be paid once Amer opened a new bank account. As stated in our response of December 5, 2019 to the Staff’s
letter dated October 16, 2019, Amer was a joint venture in which Ideanomics’ owned 55% of the equity and had control of the
Board. Given that Amer was a joint venture, rather than a wholly owned subsidiary, it was determined that having another Ideanomics’
entity receive the cash on behalf of Amer would potentially give rise to tax and regulatory reporting issues and consequently it
was decided not to pursue the option of having customer payments sent to a bank held by another entity in the Ideanomics corporate
structure.

The Amer subsidiary was sold on August 31, 2019. The disposal
was disclosed in note 5 (h) in our Form 10-Q filing for the quarter ended September 30, 2019.

Note 12. Convertible Note, page F-55

 11. We note in the last paragraph that IDV has registration rights that require the Company to file and register the common
stock issued or issuable upon conversion of the convertible note or the exercise of the warrants, within 180 days following the
closing of the transaction. Please clarify

• what constitutes an event of default pursuant
to the note indenture,

An Event of Default requires an occurrence of one of the defined
Events of default - see attached Appendix A for full details of the Events of Default – and a declaration by
the note Holder under Section 8 (b) that an Event of Default has occurred. The note holder did not call a Default under Section
8. (b). The Company has a long relationship with the note holder ID Venturas 7 LLC and is in continuing contact with them.

• whether such default triggers cross defaults
in your other note agreements, and

A Default in relation to the failure to
file and register the common stock would not constitute a Default under the other outstanding notes.

• what remedies do the note holders have,
if any, in connection with each default.

The remedies for a Default are set out
in Section 1. Definitions under Mandatory Default Amount, the full text of the definition is included in Appendix A. To summarize,
the Mandatory Default Amount requires immediate repayment of all monies due under the note.

Note 14. Related Party Transactions

(b) Transactions with GTD

Disposal of Assets in exchange of GTB, page F-57

 12. Tell us how to reconcile the significant variance between the resultant value of $3.76 per token in the revenue arrangement
and $16.32 per token received in the non-monetary exchange. In this regard, we note that you received the tokens in connection
with contemporaneous transactions involving the same counterparty.

Additionally, tell us the third party valuation
report's basis for its expected cash flows assumptions underlying the income approach which it used to determine the fair value
of the licensed content. In this regard, we note that you have not earned income or generated cash flows from such license during
the past two years.

The attached Accounting Memo prepared for the GTD transactions
provides the most complete response to the staff’s question.

Should you have any further questions or comments regarding
the captioned filings and/or this letter, please direct them to me at (212) 206-1216 or William N. Haddad, Esq. of Venable LLP,
counsel to the Company at (212) 503-9812.

Very truly yours,

    /s/ Alfred Poor

    Alfred Poor

    Chief Executive Officer

cc: William N. Haddad, Esq., Venable LLP

Appendix A

ID Venturas 7 LLC – Note maturing August 22, 2020
 – extract of provisions relating to Default

Section 8 Events of Default

    a) “Event of Default” means, wherever used herein, any of the following events (whatever the reason for such event and whether such event shall be voluntary or involuntary or effected by operation of law or pursuant to any judgment, decree or order of any court, or any order, rule or regulation of any administrative or governmental body):

    i. any default in the payment of (A) the principal amount of any Debenture or (B) interest, liquidated damages and other amounts owing to a Holder under any Debenture, as and when the same shall become due and payable (whether on a Conversion Date, Optional Redemption Date, or the Maturity Date or by acceleration or otherwise) which default, solely in the case of a default under clause (B) above, is not cured within three (3) Trading Days;

    ii. the Company shall fail to observe or perform any other covenant or agreement contained in the Debentures (other than a breach by the Company of its obligations to deliver shares of Common Stock to the Holder upon conversion, which breach is addressed in clause (xi) below) or in any Transaction Document, which failure is not cured, if possible to cure, within the earlier to occur of (A) ten (10) Trading Days after notice of such failure sent by the Ho

CORRESP
1
filename1.htm

Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

January 9, 2020

U. S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn Jacobson

Robert Littlepage

Paul Fischer

Celeste Murphy

Re: Ideanomics, Inc.

Form 10-K for the Year Ended December 31, 2018 Filed April
1, 2019

Form 10-Q/A for the Quarter Ended March 31, 2019 Filed July
16, 2019

Form 10-Q for the Quarter Ended June 30, 2019 Filed August
14, 2019

File No. 001-35561

Dear Mr. Fischer and Ms. Murphy:

On behalf of Ideanomics, Inc., a Nevada corporation (the “Company”),
we submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter on October 16, 2019 (the “Comment Letter”) with respect to the
Company’s above referenced Forms.

For the convenience of the Staff, the numbering of the
paragraphs below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated
into this response letter for convenience in italicized type and which is followed by the Company’s response. In the
responses below, page number references are to the Registration Statement.

Form 10-Q/A for Quarter Ended March 31, 2019

Item 2. Management’s Discussion & Analysis of
Financial condition and Results of Operations

Selling, general and administrative expenses, page 33

We note your response to comment seven and the disclosure
provided in Note 13(d).

Please clarify in MD&A where in your income statement
you reported the $837,000 in

total salary, severance and other expenses, and advise us.

In response to the Staff’s comment, the severance expense
of $837,000 was recorded in SG&A expense. We have updated the MD&A in our Form 10-Q filing for the period ended September
30, 2019 to include an explicit reference to this expense.

Form 10-Q/A for Quarter Ended June 30, 2019

Note 1. Nature of Operations and Summary of Significant Accounting
Policies

Digital Currency, page 11

2.       We note your
response to comments one and four and your disclosure here under that GTB holders have "the right to access the applications
built with GTD Payment Blockchain." In your response to prior comment six in your letter dated July 16, 2019,you stated that
 "ownership of GTB does not represent a right to access GD's platform." Please help us reconcile the inconsistencies
in your statements.

Ownership of GTB provides holders with the right to access
applications built within the GTD Payment Blockchain environment. Such applications include software services built on the GTD
Payment Blockchain environment.

The response in our letter dated July 16, 2019 further clarifies
that GTB ownership does not provide holders with rights or access to the underlying GTD Payment Blockchain codebase nor the ability
to make any modifications to the GTD Payment Blockchain or platform via other means. Holders of GTB have access to applications
built on the GTD blockchain but not to the blockchain itself. For example the GTD blockchain has a payment application through
which holders of GTB can pay for goods and services at participating merchants, we understand that some small retailers located
in Singapore will accept GTB as payment.

3.       With respect
to your disclosure regarding the conversion of 785,786 GTB to 2,409 Bitcoins and 17,460 Ethereum, please

• disclose your basis for determining the
values of the digital currencies and any resultant gain or loss;

The values of GTB denominated Bitcoins and GTB denominated
Ethereum are based on the market price provided by the Asia EDX exchange on the date of each transaction, net of transaction costs
paid to the Asia EDX exchange. The value of GTB denominated Bitcoins and GTB denominated Ethereum is equal to the cost basis
of the GTB prior to conversion  . The Company accounted for the conversion
as a nonmonetary transaction, and there was no gain or loss recognized on the conversion. As of September 30, 2019, the value
of GTB denominated Bitcoins (BTC) was $23,058,645.52 , and the value of GTB denominated Ethereum
(ETH) was $3,779,466.

• explain the means, process and methods
by which the exchanges were initiated and effected in great detail;

The exchanges were initiated via the Asia EDX exchange, where
Ideanomics, Inc. has an account. The conversion of GTB took place over the period April 3, 2019 thru November 4, 2019 in order
to minimize the impact on price fluctuation in the Asia EDX exchange. During a portion of the conversion period, the Asia EDX
exchange instituted a maximum daily GTB conversion of CNY ¥200,00 (based on the market price provided by the Asia EDX exchange),
which further restricted the rate of conversion; this cap has since been removed. Ideanomics, Inc. utilized the Asia EDX exchange
to post sell offers and match with buyers via the open market.

The operational process followed to execute a conversion on
the Asia EDX exchange is as follows

 · The company holds its GTB in a GTD wallet. When we want to convert GTB to BTH & ETH a transfer is made from the GTD wallet
to the Asia EDX exchange.

 · All conversion transactions are executed on the Asia EDX exchange

 · One employee is designated with the day to day operational responsibility for GTB

 · This employee had a standing instruction to convert on a regular basis, normally daily, an amount of GTB into BTC & ETH.
Management would periodically change the amount to be converted. No conversion
trades have been executed since November 4, 2019 as management considered the exchange rate between GTB and BTC & ETH to be
unfavorable.

 · The employee signs in on their company laptop and initiates the daily conversion in the amounts agreed. Sign-in is by way of
a typical username and password combination.

 · Once the conversion trades have been initiated, the employee brings their laptop to the corporate controller who enters the
corporate password for the Company’s account on the Asia EDX exchange and approves the transaction.

 · At the end of each day the corporate controller reviews the movements on the company’s account and confirms that all
activity is authorized and valid.

• identify your subsidiary and its major
counter parties in the exchange transactions, as well as their respective locations if known; and

Ideanomics, Inc. entered into the exchange transactions via
the Asia EDX exchange, and counterparties were matched via the exchange’s matching engine. As part of each transaction,
the Asia EDX exchange was paid a fee deducted from the assets converted. The major counterparties to the Company in the exchange
transactions and their respective locations are not known. No consolidated subsidiaries of Ideanomics, Inc. were party to this
exchange, or any transactions, conversions, or holding of GTB.

• how such counterparties will be able to
monetize and distribute their GTB holdings.

As noted in Item 1A. Risk Factors of our September 30, 2019
10-Q, the Asia EDX exchange has not permitted us to convert any part of our holdings of GTB, Bitcoin & Ethereum to fiat. The
Asia EDX exchange is, to date, the only cryptocurrency exchange currently making markets for GTB and does not currently offer
fiat pairs to any user. We are in regular contact with the Asia EDX exchange regarding the ability to convert some or all of our
holdings to fiat, and we have been informed that the exchange plans to introduce a capability to allow convertibility into fiat.
It is possible that the Asia EDX exchange may never allow GTB, Bitcoin & Ethereum held at the exchange to be converted into
fiat or it may take an extended period of time to convert GTB, Bitcoin & Ethereum to fiat.

In addition, because converting our holdings to fiat currency
will likely take an extended period of time, if the Asia EDX exchange were to cease operations or no longer quote GTB, there would
be no trading platform for GTB, and it would likely be impossible to convert GTB into fiat currency.   Additionally,
on page 19 of our September 30, 2019 10-Q in the Notes to Unaudited Consolidated Financial Statements in the section dealing with
Digital Currency we included the following sentence – “The company is unable to predict when our cryptocurrency holdings
will be convertible into fiat and consequently does not consider them to be part of the company’s liquid resources”

4.       We note your
statements that GTB has been actively trading on Asia EDX Exchange. Please provide us a year-to-date trading history of GTB on
the Asia EDX Exchange, including as of each trading date, its price (open, high, low, close), volume, its circulating supply,
and market cap. Include a link to an independent third party which contains the requested information.

The Asia EDX exchange does not offer historical pricing or trade
history via its website (https://www.asiaedx.com/#/). The requested information is not provided from an independent third party.
In order to maintain appropriate books and records.  Ideanomics, Inc. maintains a price history file of the daily GTB/BTC price
sourced from the Asia EDX exchange, including the open, high, low, close, and volume for each day. 10pm EST was used as the close
time, as the Asia EDX exchange does not close. These files are attached.

Note 5, Accounts Receivable, page 15

We note your response to comment five. On page 26, under
Concentration of Credit Risks, you disclosed that as of June 30, 2019 and December 31, 2018, the Company's cash was held by financial
institutions (located in the PRC, Hong Kong, the United States and Singapore). It is unclear to us why the closing and reopening
of any one bank account can affect certain customers' ability to pay. Tell us why the subject bank account was closed, why you
are experiencing a delay in reopening it, and why your customers' payments cannot be diverted to any of the other bank accounts.
Additionally, tell us in detail what your options are in connection with your right to enforce payment.

In response to the Staff’s comment, Amer was a joint venture
in which Ideanomics’ owned 55% of the equity and had control of the Board. Given that Amer was a joint venture, rather than
a wholly owned subsidiary, it was determined that having another Ideanomics’ entity receive the cash on behalf of Amer would
potentially give rise to tax and regulatory reporting issues and consequently it was decided not to pursue the option of having
customer payments sent to a bank held by another entity in the Ideanomics corporate structure.

The Amer subsidiary was sold on August 31, 2019. The disposal
was disclosed in note 5 (h) in our Form 10-Q filing for the quarter ended September 30, 2019.

Should you have any further questions or comments regarding
the captioned filings and/or this letter, please direct them to me at (212) 206-1216 or William N. Haddad, Esq. of Venable LLP,
counsel to the Company at (212) 503-9812.

    Very truly yours,

    /s/ Alfred Poor

    Alfred Poor

    Chief Executive Officer

 cc: William N. Haddad, Esq., Venable LLP