55 Broadway, 19th Floor

New York, NY 10006


July 17, 2020




U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Mr. Matthew Derby & Ms. Jan Woo


Re:Ideanomics, Inc.

Registration Statement on Form S-3

File Number 333-239371



Ladies and Gentlemen:


In accordance with Rule 461 under the Securities Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-3, File Number 333-239371, so that it will be declared effective on Tuesday July 21, 2020 at 12:00 p.m. Eastern Time, or as soon as practicable thereafter.


This letter will confirm that the Company acknowledges that:


  should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;


  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and


  the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


Please contact our legal counsel, William N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.


  Very truly yours,
  Ideanomics, Inc.
  By:   /s/ Alfred Poor
  Name:   Alfred Poor
  Title:   Chief Executive Officer