September 12, 2019

Sean T. Donaghy
Chief Financial Officer
Ebix, Inc.
1 Ebix Way
Johns Creek, Georgia 30097

       Re: Ebix, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2019
           File No. 000-15946

Dear Mr. Donaghy:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-Q for the quarterly period ended June 30, 2019

Revenue Recognition, page 17

1.    Your revenue recognition policy footnote should provide greater detail
into how you
      recognize revenue for each distinct performance obligation within a
contract. You should
      describe any significant judgments applied including how you determined
the timing of
      satisfaction of the performance obligation and the transaction price. We
refer you to ASC
      606-10-25-14 and 25-31 to 25-32. Further, the disclosure should clearly
describe how
      progress is measured and why the methods used provide a faithful
depiction of the transfer
      of goods or services. We refer you to ASC 606-10-25-33. The impact of
variable
      consideration included in your contracts should be clearly described. We
refer you to
      ASC 606-10-32-40. Please provide a proposed footnote disclosure that
provides the
      information outlined in ASC 606-10-50. The footnote disclosure should
emphasize your
      current policy under ASC 606 instead of ASC 605.
 Sean T. Donaghy
Ebix, Inc.
September 12, 2019
Page 2
2.     You disclose that "Gift voucher revenue is recognized at full purchase
value at time of
       sale with the corresponding cost of vouchers recorded under direct
expenses". Please
       provide an analysis that supports presenting this revenue on a gross
basis instead of a net
       basis. We refer you to ASC 606-10-55-36. In addition, tell us the amount
of revenue
       recognized from this revenue stream.
Costs to Obtain and Fulfill a Contract, page 18

3.     Please explain in detail how your policy of capitalizing cost to fulfill
and obtain a contract
       complies with ASC 340-40-25-1 and 25-5.
Accounts Receivable and the Allowance for Doubtful Accounts, page 19

4.     Please clarify how you account for contract assets under ASC
606-10-45-3. In addition,
       please clarify your statement that "The Company has $35.2 million of
receivables that are
       due from a public sector entity in India. Payment of these receivables
is dependent on the
       approval of funding". In this regard, please explain why you believe
revenue recognition
       is appropriate under these arrangements. Identify the significant
judgments employed in
       this case. Also, please explain how you determined that Ebix Vayam
Limited JV $35.2
       million of accounts receivable with Vayam is collectible (see your page
36).
Contract Liabilities, page 19

5.     You disclose that "The remaining portion of the contract liabilities
balance consists
       primarily of customer-specific customizations that are not distinct from
related
       performance obligations that transfer over time. This portion is
recognized over the
       expected useful life of the customizations". Please clarify the method
of measuring
       progress for these performance obligations. We refer you to ASC
606-10-25-33.
       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.

       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 with any questions.



                                                              Sincerely,

FirstName LastNameSean T. Donaghy                             Division of
Corporation Finance
                                                              Office of
Information Technologies
Comapany NameEbix, Inc.
                                                              and Services
September 12, 2019 Page 2
cc:       Robin Raina, Chief Executive Officer
FirstName LastName