United States securities and exchange commission logo





                              August 28, 2023

       Jonathan Bates
       Chief Executive Officer
       Bitmine Immersion Technologies, Inc.
       2030 Powers Ferry Road SE
       Suite 212
       Atlanta, Georgia 30339

                                                        Re: Bitmine Immersion
Technologies, Inc.
                                                            Form 10-K Filed
December 9, 2022
                                                            Form 10-Q Filed
July 14, 2023
                                                            File No. 000-56220

       Dear Jonathan Bates:

              We have reviewed your filing 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.

       Form 10-K for the Period Ended August 31, 2022

       General

   1.                                                   Provide disclosure of
any significant crypto asset market developments material to
                                                        understanding or
assessing your business, financial condition and results of operations, or
                                                        share price since your
last reporting period, including any material impact from the price
                                                        volatility of crypto
assets. In addition, and to the extent material, discuss how recent
                                                        bankruptcies in the
crypto asset market and the downstream effects of those bankruptcies
                                                        have impacted or may
impact your business, financial condition, customers, and
                                                        counterparties, either
directly or indirectly. Clarify whether you have material assets that
                                                        may not be recovered
due to the bankruptcies or may otherwise be lost or
                                                        misappropriated.
   2.                                                   If material to an
understanding of your business, describe any direct or indirect exposures
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 2 28, 2023 Page 2
FirstName LastName
         to other counterparties, customers, custodians, or other participants
in crypto asset
         markets, including Gemini, known to:
             Have filed for bankruptcy, been decreed insolvent or bankrupt,
made any assignment
              for the benefit of creditors, or have had a receiver appointed
for them.
             Have experienced excessive redemptions or suspended redemptions or
withdrawals
              of crypto assets.
             Have the crypto assets of their customers unaccounted for.
             Have experienced material corporate compliance failures.
         Please also revise your risk factor disclosure as appropriate.
Item 1. Business, page 1

3.       Describe your plan of operations for the next 12 months, providing
specific details of your
         plan, including milestones, the anticipated timeframe for beginning
and completing each
         milestone, anticipated expenses associated with each milestone and the
expected sources
         of funding. Please explain how the company intends to meet each of the
milestones if it
         cannot receive funding. Refer to Item 101(a)(2) of Regulation S-K.
4.       Please provide a quantified breakeven analysis that compares the cost
to earn/mine the
         crypto assets with the value of those crypto assets.
Company Overview, page 2

5.       Please expand your disclosure regarding the joint arrangement entered
for a location and
         power purchase agreement in Pecos, Texas to include the parties and
material terms
         including any termination provisions and file the agreement as an
exhibit.
6.       Refer to your statement "[W]e have the right to terminate our
agreement with TSTT at any
         time that the price for electricity consumption exceeds $0.05 per kwh"
and advise us of
         the basis for this termination right. Also, if any Statements of Work
have been executed,
         please file these as exhibits or advise.
7.       We note your statement in the penultimate paragraph on page 2 and the
second bullet
         point on page 3 and on page 51 that your mining activities are    in
exchange for digital
         asset rewards (primarily bitcoin).    Please tell us, and disclose in
future filings, any other
         crypto assets received and clarify your use of    primarily.
8.       We note your disclosure on pages 2 and 58 that you participate in
mining pools and
         have executed contracts "with the mining pool operators to provide
computing power to
         the mining pool." With regards to your hosting service, please clarify
whether hosting
         customers have full control over the pool utilized by the mining
machines held by the
         Company and whether mining rewards are paid directly to customers'
wallets by the
         mining pool or if they are paid to the Company and then disbursed to
the hosting
         customer. Please also revise to disclose:
             the mechanics of how revenues are split in the pools in which you
participate;
             the material terms of your mining pool agreements and file these
agreements
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 3 28, 2023 Page 3
FirstName LastName
              as exhibits;
                the percentage of your Bitcoin hashing power contributed to
mining pools;
                the total hashing power of each pool and the percentage thereof
contributed by
              your miners;
                how the pools hold your proportion of mining rewards and the
duration thereof; and
                whether the pool operators have insurance for theft or loss and
the risks associated
              with transferring crypto assets.
Revenue Sources, page 3

9.       You disclose that you do not have a set policy in regard to how long
you hold
         crypto assets that you receive as payment, other than to "immediately
sell digital assets as
         needed to pay operating expenses or for capital expenditures." Please
revise to discuss: (i)
         the average period between receipt of your crypto assets and the
subsequent sale and (ii)
         any risks to your liquidity caused by volatility in crypto asset
pricing.
10.      Please reconcile your disclosures on whether you hold or plan to hold
crypto assets for
         investment. For example, on page 4 you state "[w]e do not plan to hold
any digital assets
         that we receive as a long-term investment" and on page 51 you state
"we may hold our
         digital assets as investments in anticipation of continued adoption of
digital assets as a
            store of value    and a more efficient medium of exchange than
traditional fiat
         currencies."
Key Factors Affecting Our Performance
Halving, page 7

11.      Please revise to discuss the anticipated impacts of the next Bitcoin
halving and what steps
         you are taking to address or mitigate these impacts, if any. Discuss
in greater detail the
         potential impact of the decrease in the amount of Bitcoin rewards on
your revenues and on
         the economics of your mining operations.
Electricity Costs, page 8

12.      Please revise to quantify electricity costs and the electricity rates
paid for mining efforts
         for each period presented.
Our Facilities, page 10

13.      Refer to your updated disclosure on the Trinidad local utility's
intent to charge $0.09 per
         kwh for electricity supplied to your hosting containers, rather than
the 3.5 cents per kwh
         you expected to pay, and your new focus on developing hosting
locations in the United
         States and Canada where you state that rates are 16.2 cents per kwh
and 10.7 cents per
         kwh, respectively. Please update here to clarify the rate you expect
to pay for electricity in
         these replacement hosting locations. Also update disclosures in the
MD&A and
         throughout the filing to reflect how this price change will affect
your business and
         operations. In addition, please update disclosures on your Trinidad
container and
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 4 28, 2023 Page 4
FirstName LastName
         warehouse space leases and on the "permanent facilities" you reference
to clarify how
         your operations and plans are impacted by the utility's intent to
charge you $0.09 per kwh,
         including intentions regarding renewal of the leases and for the
"permanent facilities."
Mining Equipment, page 11

14.      Refer to your disclosure that your principal supplier for miners has
been Bitmain and that
         your mining business is "highly dependent upon digital asset mining
equipment suppliers
         such as Bitmain...." If significant, please quantify your reliance on
Bitmain or other digital
         asset mining equipment suppliers and revise to include a related risk
factor on your
         reliance on digital asset mining equipment suppliers such as Bitmain.
To the extent you
         are substantially dependent on any agreements with Bitmain or other
suppliers, please
         describe the material terms of such agreements and file the agreements
as exhibits. If you
         believe you are not substantially dependent on the agreements, please
provide us with an
         analysis supporting your belief. See Item See Item 101(h)(4)(v) of
Regulation S-K.
Item 1A. Risk Factors, page 12

15.      Please revise your risk factor disclosure to address the following
risks, to the extent
         material:
             Discuss any reputational harm you may face in light of the recent
disruption in the
             crypto asset markets. For example, discuss how market conditions
have affected how
             your business is perceived by customers, counterparties, and
regulators, and whether
             there is a material impact on your operations or financial
condition.
             Describe any material risks to your business from the possibility
of regulatory
             developments related to crypto assets and crypto asset markets.
Identify material
             pending crypto legislation or regulation and describe any material
effects it may have
             on your business, financial condition, and results of operations.
             Describe any material risks you face related to the assertion of
jurisdiction by U.S.
             and foreign regulators and other government entities over crypto
assets and crypto
             asset markets.
             To the extent material, describe any gaps your board or management
have identified
             with respect to risk management processes and policies in light of
current crypto asset
             market conditions as well as any changes they have made to address
those gaps.
             Describe any material financing, liquidity, or other risks you
face related to the
             impact that the current crypto asset market disruption has had,
directly or indirectly,
             on the value of the crypto assets you use as collateral or the
value of your crypto
             assets used by others as collateral.
16.      To the extent material, describe any of the following risks due to
disruptions in the crypto
         asset markets:
             Risk from depreciation in your stock price.
             Risk of loss of customer demand for your products and services.
             Financing risk, including equity and debt financing.
             Risk of increased losses or impairments in your investments or
other assets.
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 5 28, 2023 Page 5
FirstName LastName
                Risks of legal proceedings and government investigations,
pending or known to be
              threatened, in the United States or in other jurisdictions
against you or your affiliates.
                Risks from price declines or price volatility of crypto assets.
17.      Please remove your disclosure on page 32 in future filings that,
"Because there has been
         limited precedent set for the financial accounting for Bitcoin and
other digital assets and
         related revenue recognition and no official guidance has yet been
provided by the
         Financial Accounting Standards Board or the SEC, it is unclear how
companies may in
         the future be required to account for digital asset transactions and
assets and related
         revenue recognition." 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.
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 52

18.      Please tell us, and revise future filing disclosures, to quantify and
discuss the expenses
         (e.g. electricity, utilities, facilities costs, depreciation and
supplies, purchase price of
         equipment sold, shipping and value added tax on the equipment)
comprising your cost of
         sales for both hosting and mining and equipment sold.
Liquidity and Capital Resources, page 54

19.      We note your disclosure in the Liquidity section that you believe you
will have sufficient
         liquidity to fund operations for the next 12 months. Please tell us
the following:
             Given your significant losses in the periods presented and
accumulated deficit, please
              tell us, in detail, how you determined the cash flows referenced
in the Liquidity
              section will be sufficient to satisfy liquidity needs in the next
12 months, especially
              given the uncertainties surrounding the cash flows referenced
(i.e. repayment on
              container sales, the price of Bitcoin, electricity costs,
performance of joint venture,
              etc.);
             How you analyzed your ability to generate and obtain adequate
amounts of cash to
              meet your requirements in the long-term (i.e., beyond the next 12
months) as required
              by Item 303(b)(1) of Regulation S-K; and
             How your auditor - BF Borgers CPA PC - evaluated the Company's
ability to
              continue as a going concern and the need for explanatory
language.
Critical Accounting Policies, page 56

20.      We note that your financial statements include items for which the
underlying carrying
         value and valuation involves significant estimates. Please address the
following for all
         critical accounting estimates:
             Identify your critical accounting estimates or assumptions that
have had or
              you expect could have a significant impact on your financial
statements;
             Supplements, but does not duplicate, the description of accounting
policies or other
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 6 28, 2023 Page 6
FirstName LastName
              disclosures in the notes to the financial statements;
                Identify the key quantitative inputs in your baseline
estimates;
                Explain the qualitative adjustments made to the baseline
estimates;
                Discuss why each critical accounting estimate is subject to
uncertainty;
                Discuss how much each estimate and/or assumption has changed
over the relevant
              period; and
                Discuss the sensitivity of the reported amount to the methods,
assumptions and
              estimates underlying its calculation.

         Refer to Release No. 33-8350 Interpretation: Commission Guidance
Regarding
         Management's Discussion and Analysis of Financial Condition and
Results of Operations
         and Item 303(b)(3) of Regulation S-K.
Item 12. Security Ownership of Certain Beneficial Owners and Management and
Related
Stockholder Matters, page 68

21.      You disclose that the percent of common stock held by the shares
beneficially owned is
         based on 48,706,915 shares of common stock issued and outstanding as
of December 1,
         2022. We are unable to recalculate the percents disclosed.
Additionally, tell us why you
         have included unexercised warrants for common stock in shares
benefically
         owned. Based on overall materiality, please revise accordingly.
Item 15. Exhibits, Financial Statement Schedules
Statements of Cash Flows, page F-6

22.      You disclose in your cash flow statement that you received cash
proceeds of $5.2 million
         from the sale of common shares in a private placement. We also note
your disclosure that
         2,672,000 Units in the Unit offering (private placement) consisted of
an in-kind
         investment in the form of a sale of new mining equipment to the
Company for $3.3
         million. Please tell why you have reflected the in-kind exchange for
new mining
         equipment for 2,672,000 Units as cash proceeds from the sale of common
shares in a
         private placement and how you have reflected the in-kind exchange in
the purchase of
         fixed assets.
Note 1. Basis of Presentation and Summary of Significant Policies
Revenues from Digital Currency Mining and Revenues from Self-Mining, page F-8

23.      Please tell us, and revise future filings, to disclose the following:
             Who the customer is and the basis for your determination;
             Who has the discretion to set prices and or consideration in the
digital asset mining
             pools in which you participate;
             Who directs the use of your computing infrastructure used in the
pool and who
             obtains substantially all the asset   s economic benefits; and
             If the Company is a principal or agent in the arrangement.
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 7 28, 2023 Page 7
FirstName LastName
24.      We note your disclosure that for digital currency mining, including
self-mining,
         you measure consideration at fair value on the date received, which is
not materially
         different than the fair value at the contract inception or the time
you earned the award
         from the pools. Under ASC 606-10-32-21, you are required to measure
the estimated fair
         value of the noncash consideration at contract inception (that is, the
date at which the
         criteria in ASC 606-10-25-1 are met). Your disclosure that you measure
the consideration
         at fair value when the mining pool operator successfully places a
block and you receive
         confirmation does not appear to comply. Please address the following:
             Tell us the consideration specified in the digital currency mining
contracts;
             Tell us how you are able to determine that your policy is not
materially different than
              the fair value at contract inception. Please provide quantitative
information
              supporting this claim;
             Explain to us at what point in time contract inception occurs and
explain how you
              made the determination with appropriate reference to ASC 606; and
             Tell us the specific nature of your performance obligation under
the contract terms,
              e.g. computing power or the performance of testing nonces,
including the
              consideration for contract term and or duration and or if a
series exist. Refer to ASC
              606-10-25, paragraphs 14 and 15.
Revenues from Hosting, page F-9

25.      We note your disclosures on pages 10 and 51, that you are temporarily
leasing space for a
         small number of ASIC computers with a co-host, including warehouse
space and a 72-slot
         fan cooled container. Please address the following:
             Tell us and disclose the material terms of the co-host
agreement(s), including, but not
              limited to, the duration, rights and obligations of each party
and fee structure; and
             Provide us with an accounting analysis for the agreement(s),
including how the lease
              is reflected in the financial statements and the impact to your
revenue hosting
              arrangements.
26.      Please tell us, and enhance your disclosures in future filings, to
address the following:
             Each parties rights and performance obligations responsibilities
under your Hosting
             arrangements,
             How you determined all performance obligations are achieved
simultaneously;
             How the satisfaction of the performance obligations correlates to
the timing of
             revenue recognition of hosting services billed in U.S. dollars and
based on a
             percentage of cryptocurrency generated by the customer.
             Who directs the use of the computing infrastructure and how the
price is set in the
             arrangements.
             Why you send your hosting client its portion daily as you receive
proceeds when you
             accept the mining proceeds daily from the mining pool into a cold
wallet in your
             name;
             How you analyzed whether your hosting arrangements, in particular
those based on
             the Company   s share of cryptocurrency received from the mining
pool, include
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 8 28, 2023 Page 8
FirstName LastName
              variable consideration and whether the contracts contain a
significant financing
              component.
27.      You disclose that you accept mining proceeds directly from the mining
pool into a cold
         wallet addressed in your name. You also disclose that you send hosting
clients their
         portion daily. Please address the following regarding these
transactions:
             Tell us if the receipts from and payments to hosting clients are
with the same parties
              and or related parties;
             Provide us with a comprehensive accounting analysis for these
transactions, including
              how the entirety of the transactions are reflected in the
financial statements; and
             Provide us with your SAB 121 analysis, including your
determination of control and
              whether the Company controls the digital assets.
Cryptocurrency, page F-10

28.      Please tell us your basis and consideration for classifying impairment
expense on digital
         assets within operating expenses while the losses on sales of digital
assets within other
         income (expense). Specifically, explain how you considered whether
there is consistency
         in presentation between operating vs. non-operating classification
involving activities
         relating to the same digital assets.
29.      We note your disclosure that you classified digital assets earned by
the Company through
         its mining activities within operating activities and sales of digital
currencies within
         investing activities on the Consolidated Statements of Cash Flows.
Please provide your
         accounting analysis supporting your conclusions on their
classification on the
         Consolidated Statements of Cash Flows.
30.      We note your disclosure that the Company has an account at Gemini
Trust Company,
         LLC, which the Company only uses to transfer cryptocurrencies that it
desires to
         liquidate. Please tell us the following, and disclose in future
filings as appropriate:
             Quantify how much cryptocurrency the Company has transferred and
liquidated at
              Gemini during the historical periods; and
             Where this liquidation activity is reflected in the Company's
Consolidated Statement
              of Cash Flows.
Note 3. Revenue from Contracts with Customers, page F-12

31.      Please tell us and enhance your disclosures to explain why you have
combined hosting
         and self-mining revenue, net in your presentation of disaggregated
revenues. Refer to
         ASC 606-10-50-5.
Note 5 - Notes Receivable, page F-13

32.      Please expand your disclosure related to Notes Receivable to provide
the following:
             The specific GAAP guidance you followed to form your accounting
policy for your
             allowance for doubtful accounts;
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FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023        Immersion Technologies, Inc.
August
Page 9 28, 2023 Page 9
FirstName LastName
                Loans charged-off in the periods presented;
                Basis for inclusion of the note write-off of $168,750 in cost
of sales as disclosed on
              page 53 and authoritative guidance to support your accounting;
and
                Your charge-off policy under ASC 310-10-35-41.
Note 7. Stockholder's Equity, page F-14

33.      You disclose that in January 2022, you commenced a $10 million Unit
Offering of your
         common stock and warrants at a Unit price of $1.25 per Unit, comprised
of one share of
         common stock, one Class C-1 Warrant and one Class C-2 Warrant, that
you account for
         the issuance of equity in the Unit Offering under the guidelines of
ASC 820, Fair Value
         Measurement since your common stock is considered thinly traded and
not indicative of
         fair market value and that using the Black-Scholes method you
estimated each Class C-1
         Warrant was worth $0.41, each Class C-2 Warrant was worth $0.40, and
therefore that the
         value of the common stock sold in the Unit offering was worth $0.44.
We also note that
         subsequent to your January 2022 Unit Offering, you have utilized $.44
as the common
         stock per share value in conjunction with all common share issuances,
including as
         reflected in your 10-Q for the period ending February 28, 2023. Please
address the
         following:
             Please tell us in detail the GAAP guidance you relied upon and how
you concluded
              that the cash price paid for the shares was not a better
indication of the fair value.
             Tell us why you have continued to utilize the $.44 as the common
stock value
              considering the overall declining OTC stock price and that $3.3
million of total
              proceeds of $5.2 million in the Unit Offering was in the form of
an in-kind
              investment for hosting operation transformers; and
             Confirm to us that remaining $1.9 million in gross proceeds from
the Unit Offering
              was received in cash and from other than persons or entities
listed in Item 12.
              Security Ownership of Certain Beneficial Owners and Management
and Related
              Stockholder Matters on page 68.
34.      We note that you have classified the Series A Preferred Convertible
Preferred Stock as
         equity. Please tell us how you determined this treatment is
appropriate given the guidance
         in ASC 480 and how your current presentation is appropriate if the
holder can redeem,
         including how this is within the control of the Company. In this
regard, we note the
         Officers and Directors hold 63.9% of common stock as a group, and
Jonathan Bates,
         CEO, directly and indirectly holds 72.8% as disclosed on page 69, and
thus the Company
         is considered a "controlled company".
Note 9. Subsequent Events, page F-17

35.      You disclose that in October 2022 you entered into a Repurchase and
Hosting Agreement
         (the    TCC Agreement   ) with The Crypto Company (   TCC   ), under
which you agreed to
         repurchase certain miners previously sold in Feburary 2022 for a total
of $337,500 to TCC
         for which TCC paid 50% in cash and recognized a note receivable of
$168,750 for the
         balance. Then under the TCC Agreement, you accepted the return of the
70 Antminer TY-
 Jonathan Bates
FirstName LastNameJonathan Bates
Bitmine Immersion Technologies, Inc.
Comapany
August 28, NameBitmine
           2023         Immersion Technologies, Inc.
August
Page 1028, 2023 Page 10
FirstName LastName
         17s for a credit of $175,000, repurchased the 25 Whatsminers for
$62,500, purchased 72
         Antminer T-19s from TCC for $144,000 and the credit and purchase
prices for the
         equipment were applied to cancel the note receivable of $168,750 and
you paid $212,500
         in cash to TCC. Please address the following:
             Tell us how the original sale to TCC was recognized in the
financial statements,
              including your consideration of ASC 606-10-25-1(e);
             Tell us why you only paid $62,500 for the 25 Whatsminers
originally sold in
              February 2022 for $162,500; and
             Tell us how the repurchase, including write off of the notice
receivable of $168,750
              from TCC was recognized in the financial statements.
Form 10-Q Filed July 14, 2023

Statement of Stockholders Equity, page 7

36.      We note that during the year-ended August 31, 2022 you issued common
shares for which
         the related value would be amortized over the prospective vesting
period, including shares
         to Chris Moses, Erik Nelson, and Raymond Mow. Please tell us how you
recognized the
         related amortization in the financial statements for the nine months
ending May 31,
         2023.
Notes to Unaudited Financial Statements, page 9

37.      Please tell us, and revise future filings, to include the following
related to your Investment
         in Joint Venture of $987,429 at May 31, 2023 and the related
disclosure requirements in
         ASC 323-10-50, including:
             When this transaction occurred and the terms of the joint
arrangement, including
              what the Company received in exchange for the contribution;
             The structure, purpose and ongoing activities in order to
understand the joint venture,
              the Company's involvement, rights, obligations and operations;
             The impact on the financial statements. For example, disclose if
the contributed
              assets were de-recognized and how you are accounting for the
joint venture and its'
              activities; and
             Provide us with your comprehensive accounting analysis of the
arrangement, its
              terms and the ongoing activities of the joint venture.
Note 4. Property and Equipment, page 16

38.      Please tell us the following related to your property and equipment:
             What specific equipment the equipment not in service relates to
(i.e. miners and
             mining equipment, machinery and equipment, office and computer
equipment);
             Consider breaking out the equipment category to include the major
classes of
             depreciable assets referenced above in your rollforward. See ASC
360-10-50-1; and
             Reconcile for us the equipment not in service balance of
$3,938,427 with your
             statement in liquidity on page 29 that, "the Company owns 506
miners, most of which
 Jonathan Bates
Bitmine Immersion Technologies, Inc.
August 28, 2023
Page 11
              the Company plans to use for self-mining."

        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.

       You may contact Dave Irving at 202-551-3321 or Michelle Miller at
202-551-3368 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Sandra Hunter Berkheimer at
202-551-3758 with
any other questions.



FirstName LastNameJonathan Bates                           Sincerely,
Comapany NameBitmine Immersion Technologies, Inc.
                                                           Division of
Corporation Finance
August 28, 2023 Page 11                                    Office of Crypto
Assets
FirstName LastName