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                               July 11, 2023

       Xianfeng Yang
       Chief Executive Officer
       BIT Mining Ltd
       Units 813 &815, Level 8, Core F, Cyberport 3
       100 Cyberport Road
       Hong Kong

                                                        Re: BIT Mining Ltd
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Filed April 17,
2023
                                                            File No. 001-36206

       Dear Xianfeng Yang:

              We have reviewed your April 12, 2023 response to our comment
letter 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       March 22, 2023 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 3. Key Information, page 5

   1.                                                   Please revise here to
include the proposed disclosures provided in paragraph 1 of the
                                                        response to comment 3
in your December 30, 2022 letter.
       Cash Flows through our Organization, page 6

   2.                                                   Please revise to
include the proposed disclosures provided in comment 2 of your
                                                        December 30, 2022
response letter. In this regard, quantify and discuss any cash flows
                                                        and transfers of other
assets by type that have occurred between the holding company and
                                                        its subsidiaries, and
the direction of transfer including their tax consequences, if any, for
                                                        each period presented.
 Xianfeng Yang
BIT Mining Ltd
July 11, 2023
Page 2
Holding Company Structure, page 6

3.       Please revise to improve legibility by increasing the font size of the
text in your
         organization chart here and on page 58.
Item 5. Operating and Financial Review and Prospects
Results of Operations
The year ended December 31, 2021 compared with the year ended December 31,
2020, page 67

4.       Please revise to discuss the reasons for the negative profit margins
in your mining pool
         segment as disclosed in Note 24 and explain whether you anticipate
this trend to continue
         in future periods. We refer to comment 11 in your September 6, 2022
response letter.
Note 2. Summary of Significant Accounting Policies
Mining Pool Services, page F-25

5.       As noted in our prior comment 3, we continue to evaluate your
conclusions related to
         contract inception and contract duration as per your response to
comment 3 in your March
         1, 2023 letter.
Sub Mining Pool Services, page F-26

6.       So that we may better understand your accounting policy for sub mining
pool services,
         please address the following:
             Explain further the nature of these sub mining pool arrangements
with third-party
             pool operators.
             Clarify how these arrangements "stabilize the mining rewards" that
the Group is
             entitled to.
             Provide us your analysis as to how you determined you are the
principal such that
             revenue should be recognized gross in these arrangements. Refer to
ASC 606-10-55-
             36 to 55-40.
             Clarify whether you are deemed the mining pool participant in the
arrangement with
             the third party mining pool operator.
             Describe in detail your rationale for classifying these revenues
as mining pool
             revenues as opposed to cryptocurrency mining revenues.
Note 24. Segment Reporting, page F-61
FirstName LastNameXianfeng Yang
7.     Please revise the geographic breakdown table to explain the reference to
Blockchain as a
Comapany    NameBIT
       geographic      Mining
                   location   Ltd to the information provided in your response
to comment 14
                            similar
July 11,in2023
           yourPage
               December
                    2     30, 2022 letter.
FirstName LastName
 Xianfeng Yang
FirstName
BIT MiningLastNameXianfeng Yang
            Ltd
Comapany
July       NameBIT Mining Ltd
     11, 2023
July 11,
Page  3 2023 Page 3
FirstName LastName
       You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Technology
cc:      Yi Gao