May 5, 2025

William Horne
Chief Executive Officer
Hyperscale Data, Inc.
11411 Southern Highlands Parkway
Suite 190
Las Vegas, Nevada 89141

       Re: Hyperscale Data, Inc.
           Registration Statement on Form S-1
           Filed on April 28, 2025
           File No. 333-286788
Dear William Horne:

       We have conducted a limited review of your registration statement and
have the
following comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Form S-1 filed April 28, 2025
General

1.     Given the nature of your offering, including the size of the
transactions relative to the
       number of outstanding shares held by non-affiliates, it appears that the
transaction
       may be an indirect primary offering on behalf of the registrant. Please
provide us with
       a detailed legal analysis of your basis for determining that it is
appropriate to
       characterize the transaction as a secondary offering under Securities
Act Rule
       415(a)(1)(i). For guidance, please consider Question 612.09 of our
Securities Act
       Rules Compliance and Disclosure Interpretations.
2.     Revise your filing to specifically incorporate by reference your proxy
or information
       statements filed since the end of your fiscal year. Refer to Item
12(a)(2) of Form S-1.
 May 5, 2025
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at
202-551-3641
with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:   Kenneth A. Schlesinger