February 25, 2019

Bruno Wu
Chief Executive Officer
Ideanomics, Inc.
No. 4 Drive-in Movie Theater Park
No. 21 Liangmaqiao Road, Chaoyang District
Beijing 10015
People's Republic of China

       Re: Ideanomics, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Amended December 14, 2018
           Form 10-Q for the Quarter Ended September 30, 2018
           Filed November 14, 2018
           Response Dated December 14, 2018
           File No. 001-35561

Dear Mr. Wu:

       We have reviewed your December 14, 2018 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
September 14, 2018 letter.

Form 10-Q for the Quarter Ended September 30, 2018

1. Organization and Principal Activities, page 10

1.     Please disclose your significant judgments and analysis in evaluating
whether you
       control the consumer electronics and crude oil inventories provided by
your suppliers
       prior to their transfer to the customers. Refer to paragraphs 25, 37A
and 38 of ASC 606-
       10-55.
 Bruno Wu
Ideanomics, Inc.
February 25, 2019
Page 2
      In this regard, the indicators in ASC 606-10-55-39 may be more or less
relevant to the
      assessment of control. In particular, we note your lack of latitude in
pricing crude oil,
      considering that crude oil pricing is established through market indices
and benchmarks.


20. Subsequent Events, page 32

2.    As disclosed in your previous Form 10-Q, effective July 11, 2018, you
entered into a
      Purchase and Sale Agreement with the State of Connecticut, to purchase
the University of
      Connecticut Greater Hartford Campus for $5.2 million. Please tell us how
the transaction
      was reported in your financial statements for the quarter ended September
30, 2018.
Comparison of Three Months Ended September 30, 2018 and 2017, page 38

3.    We note your disclosure that "all revenues for the three months ended
September 30, 2018
      were generated by consumer electronics trading business in (y)our Wecast
segment."
      However, we also note that your third quarter revenues were only $43.7
million,
      compared to $132 million during the immediately preceding quarter when
you had
      attributed your revenue growth "mainly due to (y)our expanding business
of crude oil
      trading initiated in October 2017." Please disclose the causes for the
material business
      contraction during the third quarter as compared to the second quarter of
2018 and relative
      to your year-to-date revenues.
       You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3361 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 Paul
Fischer, Attorney
Advisor, at 202-551-3415 or Celeste Murphy, Legal Branch Chief at (202)
551-3257 with any
other questions.



                                                           Sincerely,
FirstName LastNameBruno Wu
                                                           Division of
Corporation Finance
Comapany NameIdeanomics, Inc.
                                                           Office of
Telecommunications
February 25, 2019 Page 2
cc:       Susan Gault-Brown
FirstName LastName