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                            September 6, 2022

       Dustin Hull
       President, Chief Financial Officer and Chief Operating Officer
       Salt Blockchain Inc.
       c/o Ballard Spahr LLP
       1735 Market Street, 51st Floor
       Philadelphia, PA 19103

                                                        Re: Salt Blockchain
Inc.
                                                            Amendment No. 4 to
Registration Statement on Form 10-12G
                                                            Filed September 10,
2021
                                                            Response Dated July
25, 2022
                                                            File No. 000-56283

       Dear Mr. Hull:

              We have reviewed your July 25, 2022 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.

       Response Dated July 25, 2022

       General

   1.                                                   We note your response
to comment 1 of our letter of May 9, 2022. Please provide us with
                                                        the following
additional information related to the derecognition model you use in
                                                        situations where you
repledge or rehypothecate borrower collateral. Specifically, provide
                                                        us a detailed analysis
that addresses the following:
                                                            Your view on
whether the counterparty to the rehypothecation meets the definition of
                                                             a customer in ASC
606-10-20, such that revenue would result from the transfer;
                                                            How you evaluated
whether you transferred control of the collateral to the
                                                             counterparty upon
rehypothecation. Refer to ASC 606-10-25-25 through 26; and
                                                            If you believe you
transferred control, how you considered the guidance in SAB 121
                                                             regarding any
obligation you have to safeguard the collateral.
 Dustin Hull
Salt Blockchain Inc.
September 6, 2022
Page 2
2.       We note your response to comment 2 of our letter of May 9, 2022.
Please tell us how you
         determined that the receivable created when the Company repledges
digital asset
         collateral is within the scope of ASC 310. In addition, tell us how
you considered whether
         the receivable contains an embedded derivative.
3.       We note the table on page F-19 in your December 31, 2021 10-K. Please
define for us
         collateral repledged for investing and collateral repledged for
financing. In addition, tell
         us whether your accounting model for derecognition is different
depending on the purpose
         for which collateral is repledged.
4.       We note your response to comment 4 of our letter of May 9, 2022 and
your responses to
         comments 30, 3, and 8 from our letters dated June 8, 2021, August 13,
2021, and October
         27, 2021, addressing the question of whether the Company is an
investment company
         under any of Section 3(a)(1) of the 1940 Act. To assess whether an
issuer is an investment
         company under Section 3(a)(1)(C), the statutory calculation must be
performed on an
         unconsolidated basis. We renew our request for a legal analysis of the
application of
         Section 3(a)(1)(C) to the Company   s business, including a breakdown
of the statutory
         calculation by its constituent parts, supported by an unconsolidated
balance sheet as of a
         recent date. Furthermore, based on the information that you have
provided to date, we do
         not have a sufficient basis upon which to concur with your view that
certain of the
         Company   s holdings in Grayscale Bitcoin Trust and Ethereum Bitcoin
Trust are not
         investment securities for purposes of Section 3(a)(1)(C). Please
provide a supplemental
         legal analysis supporting your position, with an emphasis on relevant
judicial,
         Commission and/or staff precedent.
Cover Page

5.     We note your response to comment 6 of our letter of May 9, 2022 that
"[a]s of June 2020,
       the Company became a remote-first company" and, accordingly, do not
"maintain a
       principal executive office," as well as your related cover page
disclosure that you "do not
FirstName LastNameDustin Hull
       maintain a headquarters." Please revise the cover page to provide the
address and phone
Comapany   NameSalt
       number  of yourBlockchain   Inc.
                       principal executive  offices as required by the form and
to facilitate
       compliance
September  6, 2022 with
                   PageSecurities
                         2          Exchange Act Rules 14a-8 and
14d-3(a)(2)(i).
FirstName LastName
 Dustin Hull
FirstName  LastNameDustin Hull
Salt Blockchain Inc.
Comapany 6,
September  NameSalt
              2022 Blockchain Inc.
September
Page  3    6, 2022 Page 3
FirstName LastName
        You may contact David Irving, Staff Accountant, at (202) 551-3321 or
Sharon Blume,
Accounting Branch Chief, at (202) 551-3474 if you have questions regarding
comments on the
financial statements and related matters. Please contact David Lin, Staff
Attorney, at (202) 551-
3552 or Sandra Hunter Berkheimer, Legal Branch Chief, at (202) 551-3758 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance