October 18, 2024

Matthew J. Smith
Chief Financial Officer
Stronghold Digital Mining, Inc.
595 Madison Avenue, 28th Floor
New York, NY 10022

       Re: Stronghold Digital Mining, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Response dated September 25, 2024
           File No. 001-40931
Dear Matthew J. Smith:

       We have reviewed your September 25, 2024 response to our comment 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 September 19, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 1 - Basis of Presentation and Significant Accounting Policies
Cryptocurrency Hosting Revenue, page 94

1.     We do not believe your statement that you have adopted a new accounting
policy for
       noncash consideration effective July 1, 2024 complies with the
requirements for error
       correction in ASC 250-10-45-23 and SAB 108. Please reconsider this
statement and
       tell us how you will correct the errors in accordance with the guidance
applicable to
       error corrections.
2.     Please tell us how you determined the corrected ASC 606 transaction
price for each
       hosting contract. Where helpful to an understanding, include specific
citation(s) to
       ASC 606.
 October 18, 2024
Page 2
3.    Please revise your proposed cryptocurrency hosting revenue accounting
policy to
      address the following points:
          Reorganize your disclosure to separately describe the promises, the
performance
          obligation, the consideration, the transaction price, and your timing
of
          recognition, including contract duration.
          The statement that hosting services consist of electrical power and
internet access
          appears to be inaccurate. For example, in your May 6, 2024 response
letter, you
          indicated that Stronghold promises to unload, install, provision,
maintain and
          operate customer-controlled bitcoin mining machines located at your
premises,
          including the provision of electrical power, internet access, racking
infrastructure,
          general maintenance and operations, ambient cooling, and miner
reboots for such
          mining machines.
          State your May 6, 2024 conclusion that each such promise is not
separately
          identifiable from the other promises in the contract and therefore
represents a
          single performance obligation to provide an integrated hosting
service.
          Consolidate the various statements about consideration into a single,
cohesive
          disclosure. For example, remove the statement from the first
paragraph that
          indicates the consideration for such integrated hosting service is
limited to a stated
          amount per MWh; remove the reference to    earned    in the
description of
          consideration so as to avoid confusion with your disclosure about
recognition; and
          clarify that the statement    the Company   s portion of the Bitcoin
mined    means
          that you are entitled to a portion of the Bitcoin mined by your
customers    mining
          machines that you host.
          Clarify what the transaction price is and how you determined it (see
e.g., ASC
          606-10-32-8.) Include the disclosure required by ASC 606-10-50-20.
Also, revise
          the statement that,    The Company recognizes cryptocurrency hosting
revenue to
          the extent that a significant reversal of such revenue will not
occur,    to be
          consistent with the requirements of ASC 606-10-32-11 through 32-13,
and clarify
          whether you are applying the constraint.
          Clarify your method for measuring progress toward complete
satisfaction of your
          performance obligation (see e.g, ASC 606-10-25-31 to 25-37.) Also,
make the
          disclosure required by ASC 606-10-50-18. In your response, tell us
whether you
          use the practical expedient in ASC 606-10-55-18 to measure progress
towards
          satisfying your performance obligation, and if so, explain to us why
you believe
          that practical expedient applies.
          State, if true, that the contracts have a two-year term, neither the
Company nor the
          customer can cancel or terminate the hosting agreements without
penalty before
          the two-year term elapses, and therefore you have concluded that the
accounting
          duration of the contract is two years.
          Describe the renewal options and clarify in disclosure and for us
whether they are
          material rights. For example, the consideration is not limited to a
stated amount
          per MWh, but also includes a portion of bitcoin mined by your
customers    mining
          machines.
          Make the disclosure required by ASC 606-10-50-8, 50-13, 50-17 and
50-18.
 October 18, 2024
Page 3

       Please contact Rolf Sundwall at 202-551-3105 or Bonnie Baynes at
202-551-4924 if
you have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Crypto Assets