February 10, 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
           Filed February 5, 2020
           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 Amendment No. 5 filed February 5, 2020

Issuance of common stock for True-Up related to purchase of the Delaware Board
of Trade, page
9

1.     Please disclose the number of shares that you may be required to issue
in the event your
       common stock trades at its current price on the next lock-up date in
April, 2020 pursuant
       to the terms of the True-Up provisions of the second securities purchase
agreement with
       the Delaware Board of Trade (DBOT).
Recent Developments
Impairment Charge on the Company's holdings of Cryptocurrencies, page 9

2.     We note in your response to comment 2 that "the Company has converted a
portion of its
       holdings of GTB into the more widely traded and liquid Bitcoin (BTC) and
Ethereum
 Alfred Poor
Ideanomics, Inc.
February 10, 2020
Page 2
      (ETH)". In light of your holdings of BTC and ETH, please explain to us
the basis for your
      conclusion that the Company's holdings of cryptocurrency have a de
minimis value.
Note 16. Earnings/ Loss per Common Share, page F-61

3.    Disclose the additional securities issuable pursuant to contingent stock
agreements
      (including but not limited to the DBOT security agreements with true-up
provisions) that
      could potentially dilute basic EPS in the future that were not included
in the computation
      of diluted EPS because to do so would have been antidilutive for the
period(s) presented.
      Refer to ASC 260-10-50-1(c).
       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,
Attorney-Adviser, 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
February 10, 2020 Page 2
cc:       William N. Haddad
FirstName LastName