January 27, 2020

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 December 31, 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. Unless
we note
otherwise, our references to prior comments are to comments in our August 9,
2019 letter.

Form S-1 filed December 31, 2019

The Offering, page 10

1.     We note your disclosure that approximately 20 million additional shares
will be
       outstanding after the offering. Please provide further detail as to how
these additional
       shares will become outstanding.
Overview, page 37

2.     We note your response to comment 9, the memo accompanying your
responses, the
       revised disclosure on page 37 and elsewhere in your filing. We
understand that through
       Asia EDX you distributed and traded GTB tokens in exchange for Bitcoin
and Ether. In
       light of such distribution and trading, the GTB token holders' inability
to convert such
 Alfred Poor
FirstName LastNameAlfred Poor
Ideanomics, Inc.
Comapany NameIdeanomics, Inc.
January 27, 2020
January 27, 2020 Page 2
Page 2
FirstName LastName
         tokens into fiat, and additionally, the apparent lack of functional
applications on the GTD
         blockchain, please provide us a detailed analysis and your conclusions
with respect to the
         following.
           Explain to us whether GTB tokens may be deemed a security. In this
regard, we note
              your disclosure on page 21 that "speculators and investors who
seek to profit from
              trading and holding GTB currently account for a significant
portion of GTB
              demand." On page F-47, you further state that "the value of GTB
is determined by
              the value that various market participants place on GTB through
their transactions.
              GTB holders make or lose money from buying and selling GTB." We
also note
              GTB's trading history which you provided supplementally and your
reference to the
              four-part Howey test on page 78.
           Tell us whether your distribution of GTB tokens through the Asia EDX
in exchange
              for Bitcoin and Ether may be deemed an initial exchange offering
subject to SEC
              registration.
           Explain how you concluded that GTB tokens held for trading may be
characterized as
              intangible assets. Refer us to your basis in the accounting
literature.
           Compare for us your total GTB holdings, including those which are
denominated in
              Bitcoin and Ether, to the total GTB circulating supply based on
information available
              through Asia EDX and GT Dollar.
           Explain if and when you will be able to exchange your GTB tokens
denominated in
              Bitcoin and Ether into other digital currencies. Since your
holdings of GTB tokens
              denominated in Bitcoin and Ether do not constitute direct
holdings of such currencies,
              please explain to us how the GTB/BTC and GTB/ ETH conversion
ratios (per your
              supplementary materials) were determined and when and how such
denominations
              may be converted into direct holdings. Further clarify if
settlement of the exchange
              transaction is the subject of a futures or forward contract.
           Tell us if you may be deemed a broker/dealer of GTB tokens or a
money services
              business (i.e., an administrator of the GTD blockchain) subject
to securities and
              commodities, money services and transmitter laws which you
referenced on pages
              78-79 of your filing. Please provide us a detailed evaluation of
your capacity to
              distribute and trade GTB tokens in this regard.
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page F-47

3.       We note your response to comment 6. Please expand your disclosure to
identify the
         applications that are currently functional on the GTD block chain and
the extent to which
         GTB token holders have utilized their token holdings to access such
applications. Clarify
         your disclosure to state whether Asia EDX allows such holders to
access and use their
         GTB tokens in exchange for goods and services sold by participating
merchants, absent
         any ability to convert such tokens into fiat.
 Alfred Poor
Ideanomics, Inc.
January 27, 2020
Page 3



Note 6. Accounts Receivable, page F-51

4.    We note that you sold your Amer subsidiary which had accounted for a
significant portion
      of your uncollected long-term receivables through August 31, 2019. Please
tell us your
      consideration of the Amer subsidiary as a discontinued operation pursuant
to ASC 205-
      20-45-1(B)(b). In this regard, we note that your ongoing operations
appear to constitute a
      significant strategic shift from your former trading business in 2018.
General

5.    We note your Form 8-K filing on January 10, 2020 discussing a letter from
Nasdaq's
      listing qualifications staff regarding the company's compliance with
certain listing
      standards. Please prominently disclose and discuss these developments in
your
      prospectus.
        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
William Mastrianna,
Staff Attorney at (202) 551-3778 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 Technology
January 27, 2020 Page 3
cc:       William N. Haddad
FirstName LastName