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                              November 17, 2022

       Linghui Kong
       Chief Executive Officer
       Bitdeer Technologies Group
       08 Kallang Avenue
       Aperia Tower 1, #09-03/04
       Singapore 339509

                                                        Re: Bitdeer
Technologies Group
                                                            Amendment No. 7 to
Draft Registration Statement on Form F-4
                                                            Submitted November
3, 2022
                                                            CIK No. 0001899123

       Dear Linghui Kong:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

              After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments given
       on October 25 and 26, 2022.

       Amendment No. 7 to Draft Registration Statement on Form F-4

       Bitdeer's Management's Discussion and Analysis of Financial Condition...
       Results of Operations
       Comparison of Six Months Ended June 30, 2021 and 2022, page 226

   1.                                                   Please revise to ensure
that you provide a qualitative and quantitative analysis of each of
                                                        the contributing or
offsetting factors that caused material changes in your results of
                                                        operations. In this
regard, explain and quantify the other factors contributing to the
                                                        decrease in revenue
generated from your proprietary mining business other than the price
                                                        drop of Bitcoin, such
as the comparative number of bitcoin mined and/or the amount of
 Linghui Kong
FirstName  LastNameLinghui
Bitdeer Technologies Group Kong
Comapany 17,
November   NameBitdeer
               2022     Technologies Group
November
Page 2     17, 2022 Page 2
FirstName LastName
         hash rate allocated to your proprietary mining business during each of
the periods. Also,
         in your discussion of the change in revenue generated from Cloud Hash
Rate, disclose the
         impact of generating less additional consideration from arrangements
offered under
         accelerator mode and the comparative amount of hash rate allocated to
Cloud Hash Rate
         in each of the periods. In addition, please identify if any of these
factors represent a trend
         that is reasonably expected to have a material impact.
Liquidity and Capital Resources, page 233

2.       You indicate anticipated cash flow from operations is one of the
sources of cash to meet
         your current and anticipated working capital requirements and capital
expenditures for at
         least the next 18 months. In light of the historical net cash used in
operating activities,
         please revise this disclosure and disclosures throughout your filing
indicating that you
         anticipate generating cash flow from operations.
3.       In addition to disclosing the difference between net loss and net cash
used in operating
         activities, you should also include a discussion of the underlying
reasons for changes in
         working capital items that affect operating cash flows. Your
discussion and analysis of
         operating activities should focus on the primary drivers of and other
material factors
         necessary to understand your cash flows and the indicative value of
historical cash flows.
         Please revise to provide disclosure and analysis of the underlying
factors that affect your
         operating cash flows that are not readily apparent from your cash flow
statements.
Quantitative and Qualitative Disclosure about Financial Risk, page 236

4.       Consistent with comment 36 in our letter dated January 11, 2022,
please revise to provide
         quantitative information for cryptocurrency risk exposure. Refer to
Part I, Item 11(a) of
         Form 20-F.
Bitdeer Technologies Holding Company and Subsidiaries
Notes to the Unaudited Condensed Consolidated Financial Statements
Note 20. Related Party Transactions, page F-57

5.       We continue to consider your responses to comment 3 in your letters
dated September 6,
         2022 and November 3, 2022 regarding your accounting for the wealth
management
         product and may have further comment.
6.       We continue to consider your response to comment 2 in your letter
dated November 3,
         2022 regarding your accounting of USDC lending transactions and may
have further
         comment.
7.       We note that you have entered into a loan agreement for 15 million
USDT and purchased
         type B wealth management products in the aggregate amount of 60
million USDT during
         the six months ended June 30, 2022. Further describe the material
rights and obligations
         of both parties to the loan and the investments. Please explain how
you are accounting for
         these transactions and cite the literature that supports your
accounting. As part of your
 Linghui Kong
Bitdeer Technologies Group
November 17, 2022
Page 3
         response, explain how you reached the conclusion that the
cryptocurrencies lent are not
         derecognized, as noted from your disclosure on page F-74.
Notes to the Combined and Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
p. Revenue recognition, page F-78

8.       We note your revised disclosure of your revenue recognition policy for
Cloud Hash Rate
         arrangements in response to prior comment 7. Please address the
following:

                Clarify the statement indicating that the electricity
subscriptions are sold separately,
              considering that electricity appears to be one of the two
promises that are treated as a
              single performance obligation in your arrangements;

                You indicate that the price of both plans is fixed at the
commencement of each
              subscription. Please clarify your disclosure to address whether
the transaction price
              is fixed or variable or both at the inception of the contract. In
this regard, we note
              that the unit price of the electricity subscription fee is
subject to adjustment each
              electricity subscription period; and

                We note that revenue is recognized over time and amortized
ratably throughout the
              duration of each plan. Considering you are providing a series of
distinct services and
              the unit price of the electricity subscription fee is subject to
adjustment each
              electricity subscription period, please explain how ratable
recognition is an
              appropriate method of measuring progress and clarify how you are
allocating the
              transaction price to each distinct service in the series. Also
tell us how you
              considered the guidance in paragraph 89 of IFRS 15.
9.       We note your revised disclosure of your revenue recognition policy for
Cloud Hosting
         arrangements in response to prior comment 7. You indicate that revenue
is recognized
         ratably throughout the term of the service. Please tell us if this
statement relates to only
         the fixed consideration, and, if so, please clarify your disclosure.
In this regard, we note
         that variable consideration is allocated entirely to the corresponding
distinct service
         period. In addition, please explain how ratable recognition is an
appropriate method of
         measuring progress and clarify how you are allocating the transaction
price to each
         distinct service in the series.
10.    For General Hosting arrangements, please revise to clarify the promises
in the
FirstName LastNameLinghui Kong
       arrangement and how you determined that you have a single performance
obligation. In
Comapany   NameBitdeer
       addition,          Technologies
                 please clarify         Group
                                whether you charge separate fees for the
provision of custody and
       maintenance   services.
November 17, 2022 Page 3
FirstName LastName
 Linghui Kong
FirstName  LastNameLinghui
Bitdeer Technologies Group Kong
Comapany 17,
November   NameBitdeer
               2022     Technologies Group
November
Page 4     17, 2022 Page 4
FirstName LastName
       You may contact Melissa Walsh, Senior Staff Accountant, at (202)
551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Priscilla Dao, Staff
Attorney, at (202) 551-5997 or Larry Spirgel, Office Chief, at (202) 551-3815
with any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:      Will Cai