UNITED STATES

                              SECURITIES AND EXCHANGE COMMISSION
                                          WASHINGTON ,    D . C . 20549



     DIVISION OF
CORPORATION FINANCE




                                                                August 9, 2019

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

         Re: Ideanomics, Inc.
             Registration Statement on Form S-1/A
             Filed on August 2, 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/A, filed on August 2, 2019

We are subject to risks related to holding cryptocurrencies and accepting
cryptocurrencies as a
form of payment., page 21

1.      Please revise your risk factor to address other potential risks related
to holding the GTB
        cryptocurrency you received in March, 2019, including risks related to
the storage or
        custody of the private key(s) granting access to the digital assets,
such as the threat of a
        cybersecurity breach, as well as potential risks created by events on
the underlying
        blockchain, such as "forks" and "airdrops." Please also discuss either
here or in another
        part of your prospectus your current storage and custodial practices
with respect to the
        GTB cryptocurrency.
2.      We note your statement in paragraph two that you "currently expect to
hold [y]our GTB
        unless you need cash to support your operations, at which time you may
determine to
 Alfred Poor
FirstName LastNameAlfred Poor
Ideanomics, Inc.
Comapany2019
August 9, NameIdeanomics, Inc.
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FirstName LastName
         convert to fiat currency and U.S. dollars." With a view towards
disclosure, please advise
         what consideration you gave to the inclusion of risk factor disclosure
addressing the
         possible need to register as an investment company under the
Investment Company Act.
Overview, page 36

3.       In light of your significant holdings of GTB tokens, please describe
in your MD&A
         overview your plan to monetize these tokens.
Comparison of Three Months Ended March 31, 2019 and 2018
Selling, general and administrative Expenses, page 42

4.       We note that on February 12, 2019, you entered into separate covenants
not to sue with
         certain individuals. Please disclose the significant terms of these
agreements, including
         but not limited to payable consideration of $800,000 in the aggregate,
and how you
         accounted for them in the financial statements. Refer to Exhibits
10.11, 10.12, and 10.13
         of the Form 10-Q filed on May 2, 2019 and the Form 8-K filed on
February 26, 2019.
Legal Matters, page 106

5.       We note that Sherman & Howard will pass upon the validity of the
shares you are offering
         pursuant to the registration statement, however see no Exhibit 5.1 in
your Exhibits list.
         Please file counsel's opinion as an exhibit to your filing prior to
requesting effectiveness,
         allowing sufficient time for staff review. Please refer to Item
601(b)(5)(i) of Regulation S-
         K.
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page F-47

6.       We note that GTB "is not backed by hard assets or other financial
instruments and does
         not represent an investment in GTD or a right to access GTD's
platform." If so,
         please help us reconcile this disclosure with your March 19, 2019
press release which
         reported that GT Dollar has been underwriting its tokens with
asset-backed collateral,
         including real estate, airlines, insurance as well as regional bank
clearance and acceptance,
         to launch consumer loyalty programs for those using GT Dollar when it
initially
         launched." Refer to your press release at
https://www.prnewswire.com/news-
         releases/ideanomics-signs-digital-asset-
management-services-agreement-with-
         singapores-gt-dollar-and-thai-setaku-insurance- 300814769.html.

         Additionally, it does not appear that Asia EDX Exchange
(Https://asiaedx.com) has a
         functioning website or that it is operational. Please advise us.
7.       We also note per Exhibit 10.14 of the Form 10-Q filed May 2, 2019 that
Thai Setaku
         Insurance is a counterparty to your Service Agreement with GT Dollar.
Please disclose its
         role and its respective rights and obligations in connection with the
subject agreement.
 Alfred Poor
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Ideanomics, Inc.
Comapany2019
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FirstName LastName
Note 3. Revenue
Digital asset management service with GTD, page F-49

8.       Please tell us and disclose how you adjusted the Black-Scholes option
pricing model to
         value the GT tokens. Also, please disclose how you determined the
surrogate inputs to the
         model such as the option strike price and the current stock price.
9.       Please disclose in greater detail the nature of the GT digital
currency. Clarify whether a
         GTB token as referenced in your response is the same as a GT token as
referenced in your
         service agreement. Also, disclose whether it is convertible into a
fixed or variable amount
         of conventional currency and whether you will be able to use it freely
in commerce in
         exchange for goods and services, both within and away from the GT
Dollar platform.
Note 6. Accounts Receivable, page F-51

10.      Considering that most of your receivables exceed 180 days, please tell
us why you have
         experienced significant payment delays and what amounts you received
(if any)
         subsequent to your first quarter. Tell us whether contract provisions
limit your exposure
         to credit risk and whether you have an enforceable right to payment.
If not, tell us the
         factors you considered in determining their collectability apart from
oral promises.

Note 12. Convertible Note, page F-55

11.      We note in the last paragraph that IDV has registration rights that
require the Company to
         file and register the common stock issued or issuable upon conversion
of the convertible
         note or the exercise of the warrants, within 180 days following the
closing of the
         transaction. Please clarify
           what constitutes an event of default pursuant to the note indenture,
           whether such default triggers cross defaults in your other note
agreements, and
           what remedies do the note holders have, if any, in connection with
each default.
Note 14. Related Party Transactions
(b) Transactions with GTD
Disposal of Assets in exchange of GTB, page F-57

12.      Tell us how to reconcile the significant variance between the
resultant value of $3.76 per
         token in the revenue arrangement and $16.32 per token received in the
non-monetary
         exchange. In this regard, we note that you received the tokens in
connection with
         contemporaneous transactions involving the same counterparty.

         Additionally, tell us the third party valuation report's basis for its
expected cash flows
         assumptions underlying the income approach which it used to determine
the fair value of
         the licensed content. In this regard, we note that you have not earned
income or generated
         cash flows from such license during the past two years.
 Alfred Poor
Ideanomics, Inc.
August 9, 2019
Page 4

        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.



                                                         Sincerely,
FirstName LastNameAlfred Poor
                                                         Division of
Corporation Finance
Comapany NameIdeanomics, Inc.
                                                         Office of
Telecommunications
August 9, 2019 Page 4
cc:       William N. Haddad
FirstName LastName