United States securities and exchange commission logo





                                November 16, 2021

       David Rench
       Chief Financial Officer
       Applied Blockchain, Inc.
       3811 Turtle Creek Blvd., Suite 2100
       Dallas, TX 75219

                                                        Re: Applied Blockchain,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed November 2,
2021
                                                            File No. 333-258818

       Dear Mr. Rench:

             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
September 10, 2021 letter.

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

       Risk Factors, page 7

   1.                                                   We note your added
disclosure in response to prior comment 11. Please include an
                                                        additional risk factor
highlighting this related party transaction (and any others),
                                                        highlighting the
potential for conflicts of interests and self dealing that could result from
                                                        such transactions.
       Any disruption of service experienced by certain of our third-party
service providers..., page 9

   2.                                                   We note your response
to prior comment 4; however, your added disclosure does not
                                                        address the potential
for conflicts of interest between your service providers and the
                                                        company if your service
providers are also competitors of the company. Please revise.
 David Rench
Applied Blockchain, Inc.
November 16, 2021
Page 2
Cryptoassets' assets status as a "security," a "commodity" or as a financial
instrument..., page 12

3.     Please delete the first sentence of this risk factor because without
additional clarifying
       language it is potentially misleading.
Management, page 52

4.     We note your response to prior comment 12. For each director and
executive officer,
       please state the period of service for each position such person holds
at the company (for
       example, please provide the date on which such person joined the
company). Please refer
       to Item 401(a) of Regulation S-K.
Security Ownership of Certain Beneficial Owners and Management, page 69

5.     We note your response to prior comment 13. Please further revise the
table to identify the
       two individuals who have voting power and dispositive power over the
shares held by the
       entities in the body of the table. You may include the identification of
the entities that
       hold the shares and the statements disclaiming beneficial ownership by
each individual in
       the accompanying footnotes.
3. Basis of Presentation and Significant Accounting Policies
Cryptoassets, page F-22

6.     With a view to expanded disclosure, tell us your considerations as to
whether or not you
       will use industry specific impairment testing triggers, such as an
acquisition or sale of a
       crypto-asset for a price that is materially below the carrying value of
similar crypto-assets
       held. Similarly, tell us how you determine the principal or most
advantageous market
       from which you obtain the quoted price for your crypto-assets.
        You may contact Joseph Kempf, Senior Staff Accountant, at (202)
551-3352 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Priscilla Dao, Staff
Attorney, at (202) 551-5997 or Larry Spirgel, Office Chief, at (202) 551-3815
with any other
questions.



                                                               Sincerely,
FirstName LastNameDavid Rench
                                                               Division of
Corporation Finance
Comapany NameApplied Blockchain, Inc.
                                                               Office of
Technology
November 16, 2021 Page 2
cc:       Carol Sherman
FirstName LastName