United States securities and exchange commission logo





                             March 11, 2024

       Steve Rubakh
       President Chief Executive Officer
       INTEGRATED VENTURES, INC.
       18385 Route 287
       Tioga, PA 16946

                                                        Re: INTEGRATED
VENTURES, INC.
                                                            Form 10-K for the
Fiscal Year Ended June 30, 2023
                                                            Filed September 28,
2023
                                                            File No. 000-55681

       Dear Steve Rubakh:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended June 30, 2023

       Item 1. Business, page 4

   1.                                                   We note your disclosure
throughout the document that you consider cryptocurrencies to
                                                        be investments similar
to marketable securities where you purchase and hold the
                                                        cryptocurrencies for
sale where you mark your portfolio to market at the end of each
                                                        quarterly reporting
period and report unrealized gains or losses on the investments. Please
                                                        tell us the following
related to these investments:
                                                            Where the
investments are classified on the balance sheet in the periods reported;
                                                            Where the
unrealized gains/losses are reported on the income statement in the periods
                                                             reported; and
                                                            How this disclosure
is consistent with your accounting policy on page 32, where you
                                                             disclose that you
account for digital currencies as intangible assets under ASC 350.
 Steve Rubakh
FirstName  LastNameSteve Rubakh
INTEGRATED      VENTURES,  INC.
Comapany
March      NameINTEGRATED VENTURES, INC.
       11, 2024
March2 11, 2024 Page 2
Page
FirstName LastName
Item 8. Financial Statements and Supplementary Data
Report of Independent Registered Public Accounting Firm, page 26

2.       We note in the audit opinion   s digital currencies critical audit
matter discussion that the
         audit firm asserts there is a    lack of formal GAAP and PCAOB
guidance in the United
         States    related to digital currencies. Given this statement and the
fact that the audited
         financial statements include accounting policies related to digital
currencies that
         management asserts are GAAP compliant, please explain how the auditor
was able to
         issue an unqualified audit opinion and state that the audit was
performed in accordance
         with PCAOB standards.
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Digital Currencies, page 32

3.       Please provide us a rollforward of Digital Assets for each financial
statement period
         included in your 6/30/22 10-K and 12/31/22 10-Q. Ensure that your
response includes a
         separate rollforward of each digital asset held (i.e. Bitcoin,
Dogecoin, Quant), reflects the
         revenue generated from mining each digital asset, and provides the
beginning and ending
         balance of each digital asset for each period provided.
4.       We note the statement in your digital currencies accounting policy
footnote that there is
         limited precedent regarding the classification and measurement of
cryptocurrencies under
         current GAAP. We further note the statement in your revenue
recognition accounting
         policy footnote that there is no specific definitive guidance in GAAP
for the accounting
         for the production and mining of digital currencies. We are unclear
how these statements
         are consistent with management's responsibility to provide financial
statements it asserts
         are compliant with GAAP. In that regard, we observe that the FASB
codification is the
         source of authoritative generally accepted accounting principles and
that there is
         codification guidance whose scope applies to your transactions. Please
revise your filing
         to remove this disclosure.
Revenue Recognition, page 34

5.       Please tell us, and revise your disclosure in future filings to
specifically address the
         following concerning your revenue recognition policy under ASC 606 for
mining bitcoin:
             Please revise your disclosure to identify the customer in your
bitcoin mining
              transactions and the arrangement you have with that customer. In
that regard, we
              note your disclosure on page 4 that the company participates in
mining activities
              through mining pools
             Confirm if mining pool in which you participate utilizes the Full
Pay Per Share
              (FPPS) payout method;
             If you are using the FPPS payout method, revise your disclosure to
indicate how each
              component of your contract consideration under FPPS is
calculated. In this regard, it
 Steve Rubakh
INTEGRATED VENTURES, INC.
March 11, 2024
Page 3
              appears your consideration is comprised of block rewards,
transaction fees, and
              mining pool operating fees;
                Tell us if your mining pool contract is terminable, "at any
time by either
              party without cause and without penalty," and include this
specific disclosure in
              future filings, if true;
                If your mining pool contract can be terminated at any time
without penalty, tell us
              whether you believe the contract is continuously renewed. Refer
to examples 1 and 2
              of question 7 and question 8 of the FASB Revenue Recognition
Implementation
              Guide Q&As. If so, tell us, and revise your disclosure to
discuss:
                o  Your consideration as to whether the duration of your
contracts is less than 24
                   hours;
                o  Whether the rate of payment remains the same upon renewal;
and
                o  Whether your customer   s option to renew represents a
material right that
                   represents a separate performance obligation as contemplated
in ASC 606-10-
                   55-42;
                Confirm for us whether the company decides when to provide
services under the
              mining pool contracts and if you believe that an enforceable
right to compensation
              begins when, and continues for as long as services are provided.
If this is true, please
              update your disclosure accordingly;
                We note that your performance obligation is, "providing
transaction verification
              services within the digital currency networks." Tell us your
consideration for
              disclosing your performance obligation as, "the service of
performing hash
              computations (i.e. hashrate) to the mining pool," or something
similar to more
              precisely and closely align with the promise in your contracts,
and include this
              specific disclosure in future filings, if true;
                You disclose that you fair value non-cash consideration on the
date of receipt. Tell
              us how this is consistent with the guidance in ASC 606-10-32-21,
which requires
              non-cash consideration to be value at contract inception.

       In closing, 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 David Irving at 202-551-3321 or Robert Telewicz at
202-551-3438 with
any questions.



FirstName LastNameSteve Rubakh                                  Sincerely,
Comapany NameINTEGRATED VENTURES, INC.
                                                                Division of
Corporation Finance
March 11, 2024 Page 3                                           Office of
Crypto Assets
FirstName LastName