July 5, 2019 Nadir Ali Chief Executive Officer Inpixon 2479 E. Bayshore Road, Suite 195 Palo Alto, CA 94303 Re: Inpixon Registration Statement on Form S-1 Filed June 28, 2019 File No. 333-232448 Dear Mr. Ali: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rule 461 regarding requests for acceleration. 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. Please contact Matthew Derby, Staff Attorney, at (202) 551-3334 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services cc: Melanie Figueroa, Esq.