September 20, 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 September 13, 2019
           File No. 333-233763

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 Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require
further
assistance, please contact Barbara C. Jacobs, Assistant Director, at (202)
551-3730.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Information Technologies
                                                            and Services
cc:    Melanie Figueroa, Esq.