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                           December 1, 2022

       Alfred P. Poor
       Chief Executive Officer
       Ideanomics, Inc.
       1441 Broadway, Suite 5116
       New York, NY 10018

                                                        Re: Ideanomics, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed November 7,
2022
                                                            File No. 333-267547

       Dear Alfred P. 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
October 20, 2022 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Cover Page

   1.                                                   We note your revised
disclosure in response to comment 2. Please revise where you
                                                        discuss Holding Foreign
Companies Accountable Act to also discuss the Accelerating
                                                        Holding Foreign
Companies Accountable Act.
       Control by the Chinese Government, Permission or Approval by the Chinese
Government., page
       18

   2.                                                   We note your amended
disclosure in response to comment 9. Please clearly indicate in
                                                        your disclosure whether
you relied on an opinion of counsel when determining what
                                                        permissions and
approvals are required in connection with the operation of the PRC
 Alfred P. Poor
Ideanomics, Inc.
December 1, 2022
Page 2
         subsidiaries. Additionally, please disclose each permission or
approval that you or your
         subsidiaries are required to obtain from Chinese authorities to
operate your business.
         Please also discuss the risks related to obtaining/not obtaining
required permissions and
         approvals from Chinese authorities in your Risk Factors section.
Risk Factors Summary
Risk related to our operations in China., page 19

3.       We note your response to comment 8 and your revised disclosure that
you are not a
         China-based issuer. Such statement does not appear to be consistent
with your disclosure
         that "a significant portion of our current operations is located in
mainland China and a
         significant portion of our revenue is derived from mainland China."
Please revise.

         As a related matter, please also revise your disclosure so each
summary risk factor related
         to your operations in China includes a cross-reference to the relevant
individual detailed
         risk factor.
Risks Related to Doing Business in China
In light of recent events indicating greater oversight by the CAC..., page 26

4.       We note your amended disclosure in response to comment 13. Please
clearly indicate in
         your disclosure whether you relied on an opinion of counsel when
determining whether
         PRC laws and other obligations applied to your business and this
offering.
General

5.       Please expand your disclosure throughout the registration statement to
clarify that the
         legal and operational risks associated with operating in China also
apply to your
         operations in Hong Kong.
6.       We note your revised disclosure in response to comments 3 and 10.
Please clarify which
         entity made the cash transfers discussed.

       As a related matter, we note your disclosure that the company does not
have records of
       cash transfers in and out of the VIEs for the fiscal year 2019 in
possession and your
       response to comment 11 in your letter dated November 7, 2022 that source
records from
       that period were maintained by a third party provider in China with whom
you no longer
FirstName LastNameAlfred P. Poor
       continue a service relationship. Please discuss in your risk factors
whether and how such
Comapany
       loss NameIdeanomics,
            of records impacts Inc.
                                your business and disclosure, controls and
procedures.
December 1, 2022 Page 2
FirstName LastName
 Alfred P. Poor
FirstName
Ideanomics,LastNameAlfred P. Poor
            Inc.
Comapany1,
December   NameIdeanomics,
             2022          Inc.
December
Page 3    1, 2022 Page 3
FirstName LastName
      Please contact Alyssa Wall at 202-551-8106 or Jennifer L  pez Molina at
202-551-
3792 with any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services
cc:      William N. Haddad, Esq.