SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 January
2, 2026

 U.S.
Securities & Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
 Claudia
 Rios

 Liz
 Packebusch

 Re:
 Bimergen
 Energy Corporation (f/k/a Bitech Technologies Corp.) Amendment No. 13 to Registration Statement on Form S-1

 Filed
 December 12, 2025

 File
 No. 333-280668

 To
Whom It May Concern:

 Bimergen
Energy Corporation (the " Company " or " we ") hereby transmits its response to the comment letter
received from the staff (the " Staff ") of the U.S. Securities and Exchange Commission, dated December 31, 2025 regarding
the Company's Amendment No. 13 to its Registration Statement on Form S-1/A filed on December 12, 2025 (the " Registration
Statement "). In response to the Staff's comments, the Company has filed Amendment No. 14 to its Registration Statement
on Form S-1/A on January 2, 2026. We are submitting this correspondence to further explain the Company's responses to such comments.
For the Staff's convenience, we have repeated below the Staff's comments and have followed each comment with the Company's
response.

 Amendment
No. 13 to Registration Statement on Form S-1 General

 1.
 We note your disclosure that the warrants and pre-funded warrants
may be exercised on a cashless basis, in which case the holder is entitled to receive a number of shares determined according to the
formula set forth in the respective instrument. Please revise to disclose the formula(s) governing cashless exercise and clearly state
whether the shares issued in a cashless exercise will be greater or less than the shares issued in a cash exercise.

 Response:
The Company acknowledges the Staff's comment and we have revised the registration statement within Description of Securities
We Are Offering Section to disclose the formula(s) governing cashless exercise an d clearly state whether the shares issued
in a cashless exercise will be greater or less than the shares issued in a cash exercise.

 2. Please
 update your filing fee table to reflect the changes made to your offering.

 Response:
The Company acknowledges the Staff's comment and notes that we have revised the filing fee table to reflect the changes
made to our offering.

 If the Staff has completed its review of the
Registration Statement, we would request acceleration of the Registration Statement immediately.

 We
thank the Staff for its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact
our counsel at pcampitiello@lucbro.com or by telephone at (732) 395-4517.

 Sincerely,

 BIMERGEN
 ENERGY CORPORATION

 By:
 /s/
 Robert J Brilon

 Name:
 Robert
 J. Brilon

 Title:
 Co-Chief
 Executive Officer