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CORRESP Filing

Athena Bitcoin Global
Date: May 12, 2025 · CIK: 0001095146 · Accession: 0001683168-25-003404

Regulatory Compliance

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File numbers found in text: 333-262629

Referenced dates: August 13, 2021

Date
May 12, 2025
Author
By: /s/ Matias Goldenhorn
Form
CORRESP
Company
Athena Bitcoin Global

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Finance Attention: David Lin, Staff Attorney (202) 551-6553 Re: Athena Bitcoin Global Registration Statement on Form S-1 Filed February 10, 2022 File No. 333-262629

Dear Ms. Paik and Mr. Lin:

Athena Bitcoin Global (the " Company ") hereby responds to the Staff's additional supplemental response request regarding the following former comment issued by the Staff and the Company's response in the letter dated August 13, 2021 responding to the Staff's comments:

Athena Bitcoin Global

Draft Registration Statement on Form S-1 Submitted May 5, 2021

CIK No. 0001095146

General

53. Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications. Please contact the staff member associated with the review of this submission to discuss how to submit the materials, if any, to us for our review.

In response to Staff's comments, please be advised that the Company hereby confirms that is has not used written communications, as defined in Rule 405 under the Securities Act, or anyone authorized to do so on the Company's behalf, present to potential investors in reliance on Section 5(d) of the Securities Act.

We trust that this response satisfactorily responds to your request. Should you require further information, please contact our legal counsel Iwona J. Alami at (949) 760-6880.

Very truly yours.
By: /s/ Matias Goldenhorn

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CORRESP
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 filename1.htm

 Athena Bitcoin Global

 1 SE 3rd Avenue, Suite 2740

 Miami, Florida 33131

 May 12, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Irene Paik, Staff Attorney (202) 551-6553

 David Lin, Staff Attorney (202) 551-6553

 Re:
 Athena Bitcoin Global

 Registration Statement on Form S-1 Filed February 10, 2022

 File No. 333-262629

 Dear Ms. Paik and Mr. Lin:

 Athena Bitcoin Global (the " Company ")
hereby responds to the Staff's additional supplemental response request regarding the following former comment issued by the Staff
and the Company's response in the letter dated August 13, 2021 responding to the Staff's comments:

 Athena Bitcoin Global

 Draft Registration Statement on Form S-1 Submitted May 5, 2021

 CIK No. 0001095146

 General

 53. Please supplementally provide us with copies of all
written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the
communications. Please contact the staff member associated with the review of this submission to discuss how to submit the
materials, if any, to us for our review.

 In response to Staff's
comments, please be advised that the Company hereby confirms that is has not used written communications, as defined in Rule 405 under
the Securities Act, or anyone authorized to do so on the Company's behalf, present
to potential investors in reliance on Section 5(d) of the Securities Act.

 We trust that this response satisfactorily responds
to your request. Should you require further information, please contact our legal counsel Iwona J. Alami at (949) 760-6880.

 Very truly yours.

 By: /s/ Matias Goldenhorn

 Chief Executive Officer

 cc: Iwona Alami, Esq.