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.
             Form 10-K for the Year Ended December 31, 2018
             Filed April 1, 2019
             Form 10-Q/A for the Quarter Ended March 31, 2019
             Filed July 16, 2019
             File No. 001-35561

Dear Mr. Poor:

       We have reviewed your filing 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-Q/A for the Quarter Ended March 31, 2019

Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page 11

1.      We note your response to comment six and your statement that there are
"no underlying
        assets associated with GTB and ownership of GTB does not represent a
right to access
        GD's platform." Please help us reconcile this representation 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-
 Alfred Poor
FirstName LastNameAlfred Poor
Ideanomics, Inc.
Comapany2019
August 9, NameIdeanomics, Inc.
August 9, 2019 Page 2
Page 2
FirstName LastName
         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.
2.       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.
Note 3. Revenue
Digital asset management service with GTD, page 13

3.       We note your response to comment seven. Please tell and disclose us
how you
         adjusted the Black-Scholes option pricing model to value the GT
tokens. In particular,
         please disclose how you determined the surrogate inputs to the model
such as the option
         strike price and the current stock price.
4.       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 15

5.       We note your response to comment five and your revised disclosure.
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 14. Related Party Transactions
(b) Transactions with GTD
Disposal of Assets in exchange of GTB, page 21

6.       We note your response to comment nine. 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
 Alfred Poor
Ideanomics, Inc.
August 9, 2019
Page 3
      cash flows from such license during the past two years.
Selling, general and administrative Expenses, page 33

7.    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.
Correspondence Filed July 16, 2019

Letter Header, page 1

8.    Please resubmit your correspondence dated July 16, 2019 to remove the
official SEC
      letterhead and the signature line referencing the Division of Corporation
Finance Office of
      Telecommunications on pages one and seven respectively.
        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
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 3
cc:       William N. Haddad
FirstName LastName