Ideanomics Inc (IDEX)

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Info regarding Bitcoin and Ethereum holdings for IDEX:

https://docoh.com/filing/837852/0001104659-20-017753/IDEX-CORRESP and read this below from this page:

By way of introduction. The Company’s holdings of cryptocurrency are reported as holdings of GTB, Bitcoin (BTC) and Ethereum (ETH) in the Company’s account held at the AsiaEDX Exchange. However, as the Company has disclosed on page F-47 of its S-1/A filing dated February 5, 2020 the holdings of BTC and ETH represent GTB denominated in Bitcoin & Ethereum and as such donot represent a direct holding of BTC & ETH. Because the Company does not have a direct holding in Bitcoin and Ethereum, changes in the value of the Company’s Bitcoin & Ethereum are driven by changes in the GTB price and not the prices for Bitcoin & Ethereum.

Furthermore, on page F-46 of the February 5, 2020 S-1/A filing the Company has included the following disclosure… “To date the company has not been able to convert any of its crypto currency holdings to fiat. The Asia EDX exchange has indicated that it continues work towards providing exchangeability for coins held on the exchange into fiat. Management is unable to give any assurance as to when, if ever, the Asia EDX exchange will permit conversion of the company’s crypto currency holdings into fiat”

The Company concluded that its holdings of BTC and ETH should be valued at a de minimis amount because there is no assurance that these holdings can ever be converted to fiat and the underlying driver of the value of its holdings of BTC & ETH is the price of GTB and not the prices for BTC & ETH.

In response to Staff comments made subsequent to a conference call on February 11, 2020 between the Company and the Staff, the Company has removed all references to Bitcoin (BTC) and Ethereum (ETC) in its S-1A filing dated 2-12-2020