November 13, 2024

Raymond Mow
Chief Financial Officer
Bitmine Immersion Technologies, Inc.
2030 Powers Ferry Road SE
Suite 212
Atlanta, Georgia 30339

       Re: Bitmine Immersion Technologies, Inc.
           Form 10-K for Fiscal Year Ended August 31, 2023
           Response dated October 4, 2024
           File No. 000-56220
Dear Raymond Mow:

       We have reviewed your October 4, 2024 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our July 8,
2024 letter.

Form 10-K for Fiscal Year Ended August 31, 2023
Part I
Item 1, Business, page 1

1.     We note your response to prior comment 2. Please file draft disclosure
of your
       breakeven analysis as correspondence on EDGAR, that you plan to include
in your
       next periodic report, that includes an estimate of the financing costs
of your miners.
       Please add any explanatory disclosure you deem necessary, in addition to
disclosing
       an estimate of your financing costs, to discuss any assumptions and
limitations
       relevant to the financing cost estimate that you disclose.
2.     In that draft disclosure please address the following matters regarding
your breakeven
       analysis:
           Please explain why your footnote states that "Other direct costs of
mining - non
 November 13, 2024
Page 2

           energy utilities per bitcoin mined" includes electricity if this
line is for "non
           energy" utilities.
             Please clarify where depreciation of your mining equipment is
reflected under
           both "Cost of Mining - owned facilities" and "Cost of Mining -
hosted facilities."
             By footnote or other means, under "Statistics - hosted facilities"
please disclose
           what is included in "Other direct costs of mining - non energy
utilities."

       Please contact David 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 John Dana Brown
at 202-551-
3859 with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Crypto
Assets