February 5, 2020

Robert Kerris
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 September 30, 2019
           File No. 000-15946

Dear Mr. Kerris:

       We have reviewed your filing 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 September 30, 2019

Revenue Recognition, page 17

1.    Tell us the amount of revenue recognized related to the set up and
customization services
      that are considered a single performance obligation with the SaaS
platform service for the
      periods presented. To the extent material, further explain why you
believe these
      customizations significantly modify the nature of the services you
provide over the SaaS
      platform as you note in your response to prior comment 1.
2.    Your disclosures indicate that certain services depend on significant
levels of integration
      and interdependency between the licensed software and additional
services. Clarify for us
      and in your disclosures whether the setup and customization services are
considered one
      performance obligation with the SaaS platform service or with the
licensed software.
      Further, tell us and disclose when revenue is recognized for the licensed
software
      delivered in these arrangements.
 Robert Kerris
Ebix, Inc.
February 5, 2020
Page 2
3.     Your proposed disclosure indicates that the SaaS Platform fees and the
services are
       recognized over the contract term; however, your current disclosures
states that these
       services (setup and customization) are recognized over their expected
useful life, which
       may exceed the currently contracted term. Please clarify for us which of
these is your
       current policy. To the extent it is the latter, tell us your basis for
recognizing revenue
       beyond the contract term with reference to the accounting guidance
followed.
        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 if you have questions.



                                                             Sincerely,
FirstName LastNameRobert Kerris
                                                             Division of
Corporation Finance
Comapany NameEbix, Inc.
                                                             Office of
Technology
February 5, 2020 Page 2
cc:       Robin Raina, Chief Executive Officer
FirstName LastName