June 3, 2019

Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006

       Re: Ideanomics, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed on May 7, 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.

Registration Statement on Form S-1 filed May 7, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
35

1.     We note you state that you have begun phasing out of the crude oil
trading business and
       the electronics trading business. Please expand your MD&A and financial
statement
       footnote disclosures to address the following, as appropriate, and
advise us in detail.
         Indicate whether you have tested the related asset groups for
recoverability based on
           their shortened useful lives and, if so, tell us the results of this
testing.
         Explain to us your consideration of presenting these businesses as
discontinued
           operations. In this regard, it is unclear if you have ceased to use
long-lived assets and
           if so, whether they should be considered abandoned. We refer you to
the guidance in
           ASC 205-20-45 and ASC 360-10-35-47.
 Alfred Poor
Ideanomics, Inc.
June 3, 2019
Page 2
             Clearly disclose whether or not you anticipate earning any revenue
from these
             businesses in the future.

Financial Statements, page F-1

2.       Please provide condensed financial statements of the registrant,
pursuant to 5-04 of
         Regulation S-X, or advise us. The financial statements should provide
the information
         required by 12-04 of Regulation S-X.
Note 5. VIE Structure and Arrangements, page F-17

3.       Please expand your disclosure to fully comply with 4-08(e)(3) of
Regulation S-X with
         respect to your PRC based subsidiaries.
Acquisition of Tree Motion Sdn. Bhd. ("Tree Motion"), page F-38

4.       Please provide audited financial statements of Tree Motion pursuant to
8-04 of Regulation
         of S-X or explain to us why it is not necessary to do so. It also
appears you should
         provide pro forma financial information pursuant to 8-05 of Regulation
S-X.
Note 22. Subsequent Event
Disposal of Assets in exchange of GTDollar coins, page F-38

5.       Please explain to us your consideration of reporting the YOD business
as discontinued
         operation. In this regard, we note on page 40 that you did not
generate any revenue from
         your YOD Legacy business during all of 2018 and its license content
(carrying amount of
         $17 million) was sold in 2019. Refer to ASC 205-20-45-1.
6.       It is unclear why you disclose that you received GTDollar coins in
exchange for certain
         assets while on page 21 of your March 31, 2019 Form 10-Q you disclose
you received
         GTB tokens. Please revise so that your disclosures are consistent and
advise us.
        You may contact Kathryn Jacobson, Senior Staff Accountant, at
202-551-3365, or Robert
S. Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Celeste M. Murphy, Legal Branch Chief, at
202-551-3257, with
any other questions.



FirstName LastNameAlfred Poor                                Sincerely,
Comapany NameIdeanomics, Inc.
                                                             Division of
Corporation Finance
June 3, 2019 Page 2                                          Office of
Telecommunications
FirstName LastName