June 11, 2019

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 March 31, 2019
           Filed May 2, 2019
           File No. 001-35561

Dear Mr. Poor:

       We have reviewed your filings 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-K for the Year Ended December 31, 2018

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Overview, page 44

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
FirstName LastNameAlfred Poor
Ideanomics, Inc.
Comapany NameIdeanomics, Inc.
June 11, 2019
June 11, 2019 Page 2
Page 2
FirstName LastName

             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 22. Subsequent Event
Disposal of Assets in exchange of GTDollar coins, page F-38

3.       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.
4.       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.
Form 10-Q for the Quarter Ended March 31, 2019

Consolidated Balance Sheets, page 4, page 4

5.       It appears that your account receivable outstanding as of December 31,
2018 and March
         31, 2019 relate to your oil and electronics consumer products trading
businesses which
         had been phased out. Please include a note in the financial statements
addressing the
         aging, terms and collectability of these receivables.
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Tokens, page 11

6.       Provide us with a more detailed discussion of your rights and
obligations as a token holder
         and those of GTD, the token issuer. It is unclear to us whether the
underlying asset of your
         GTB tokens which you hold as part of your "digital asset management
service" represents
          an investment in GD or a right to access GD's platform (if
operational). Further clarify
         whether the GTB tokens trade on Asia EDX Exchange or Asia EDX OTC per
your
         disclosure on page 37.
Note 3. Revenue , page 13

7.       Please disclose the input parameters and valuation technique that you
used to measure the
         fair value of 7,083,333 GTB tokens received from GTD, your minority
shareholder. Refer
         to ASC 820-10-50-1.
 Alfred Poor
Ideanomics, Inc.
June 11, 2019
Page 3
Note 6. Property, Plant and Equipment, net , page 15

8.    Please disaggregate the cost of the land and buildings related to the
University of
      Connecticut Hartford Campus from the Construction in Progress.
Disposal of Assets in Exchange for GTB Tokens, page 21

9.    We note your statement that in the disclosed nonmonetary exchange
transaction, the fair
      values of GTB tokens are not reasonably determinable and therefore, you
recorded the
      transaction with no gain or loss based on the carrying amounts of the
assets relinquished.
      However, such accounting treatment is applicable only when "the fair
value of neither the
      asset(s) received nor the asset(s) relinquished is determinable within
reasonable limits."
      Refer to condition (a) of ASC 845-10-30-3. In this regard, tell us the
following:
        Why you concluded that the fair value of the GTB tokens is not
          reasonably determinable. In this regard, we note that you recorded
your 2019
          revenues based on the fair value of GTB tokens received.
        How you considered the fair value of the assets relinquished.
        Whether you tested the relinquished assets for recoverability while
held and used.
        Whether you tested the relinquished assets for impairment prior to
their disposal.
        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 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 Paul
Fischer, Attorney
Advisor at (202) -551-3415 or Celeste Murphy, Legal Branch Chief at (202)
551-3257 with any
other questions.



                                                            Sincerely,
FirstName LastNameAlfred Poor
                                                            Division of
Corporation Finance
Comapany NameIdeanomics, Inc.
                                                            Office of
Telecommunications
June 11, 2019 Page 3
cc:       Susan Gault-Brown
FirstName LastName