United States securities and exchange commission logo





                              August 17, 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 July 25, 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
       July 11, 2023 letter.

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

       Item 5. Operating and Financial Review Prospects Results of Operations
       The year ended December 31, 2022 compared with the year ended December
31, 2021, page 65

   1.                                                   We note your proposed
revised disclosures in response to prior comment 4. Please revise
                                                        to separately discuss
and quantify the revenue and cost of revenue from each of the
                                                        primary and sub mining
pool services so to better clarify the potential significant disparity
                                                        in gross profit for
each.
 Xianfeng Yang
FirstName
BIT MiningLastNameXianfeng  Yang
            Ltd
Comapany
August 17, NameBIT
           2023     Mining Ltd
August
Page 2 17, 2023 Page 2
FirstName LastName
Sub Mining Pool Services, page F-26

2.       Please address further the following as it relates to your response to
prior comment 6.
             Describe, in detail, how the technology and process work such that
you both transfer
             computing power generated by your mine pool participants to the
mining pools in
             which you participate and control the computing power of your
mining pool
             participants before you transfer it to the mining pool operators
of the mining pools in
             which you participate. For example, are you relaying the block
header, the block
             version, and the block data provided by the mine pool operator of
the mine pool in
             which you participate as well as your wallet address to the
participants in your
             mining pool?
             Specify the terms of your Agreements that provide the company with
control over the
             service of providing computing power before it is provided to the
third-party pool
             operators and the ability to transfer such service.
             Highlight any significant differences between the rights and
obligations of your mine
             pool participants and your rights and obligations in the mining
pools in which you
             participate. As part of that comparison, compare the payout
mechanism of the pool
             you operate with the pools with which you participate, identifying
each significant
             variable effecting both the block reward and transaction fee
components of those
             payouts.
             Explain to us how you receive payouts from the third-party pools
in which you
             participate, including whether you provide your wallet address to
the third-party
             operator. In this regard, clarify whether rewards are received in
BTC.com's wallet
             and then distributed to your mining pool participants' wallets.
             Summarize the material terms of, and provide us with a copy of,
the Specific Service
             Agreement that is referenced in the BTC.com User Agreement. Also,
identify the
             mining pools in which you participate and provide us with a copy
of the agreements
             that specify the rights and obligations of the parties to those
agreements.
             Provide a comprehensive accounting analysis of how you determined
that you control
             the computing power of the mining pool participant before it is
provided to third-
             party pool operators. Refer to ASC 606-10-25-25.

       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 any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Yi Gao