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                             March 16, 2022

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

                                                        Re: Applied Blockchain,
Inc.
                                                            Amendment No. 7 to
Registration Statement on Form S-1
                                                            Filed February 28,
2022
                                                            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
February 18, 2022 letter.

       Amendment No. 7 to Registration Statement on Form S-1

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Trends and Uncertainties, page 41

   1.                                                   Please revise your
discussion of trends and uncertainties as required by Items 303(b)(1)(i)
                                                        and (ii)(B) and Item
303(b)(2)(ii) of Regulation S-K. Discuss your decision to
                                                        discontinue all crypto
mining operations and address:
                                                            how you plan to
account for the cessation of your crypto mining operations;
                                                            the expected impact
of the sale of your crypto mining equipment; and
                                                            how cessation of
your crypto mining operations may affect your future liquidity and
                                                            capital resources.
 David Rench
Applied Blockchain, Inc.
March 16, 2022
Page 2
Accounting Matters, page 42

2.    We note that you plan to account for your co-hosting arrangements as a
single
      performance obligation. We also note on page 46 that you will lease space
and provide
      access to electricity, and that you will "provide full operations and
maintenance services
      for a fixed fee". Explain the contractual terms under which you will be
compensated for
      leased space, the provision of electricity and other services. Explain to
us why your
      provision of leased space and electricity and other services should be
accounted for as a
      single performance obligation under ASC 842. Also explain how you plan to
measure
      satisfaction of your co-hosting performance obligations and how such
methodologies are
      appropriate under ASC 842.
Financial Statements
Consolidated Statements of Operations (Unaudited), page F-17

3.    We note your intent to exit your mining operations and the sale of your
Bitcoin mining
      equipment. Please explain to us your consideration of presenting your
mining business as
      a discontinued operation. Specifically, tell us when you met each of the
criteria in ASC
      205-20-2-45-1E.

        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
March 16, 2022 Page 2
cc:       Carol Sherman
FirstName LastName