SecProbe.io

United States securities and exchange commission logo
March 22, 2023
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 7, 2022
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your March 1, 2023 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
February 15, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Cryptocurrency Assets, page F-18
1.We note your response to prior comment 2 where you state that you use the price quoted
each day at 0:00 UTC to determine the fair value used for impairment assessment. We do
not believe your accounting policy complies with ASC 350-30-35-19, which states in part,
“If the carrying amount of an intangible asset exceeds its fair value, an entity shall
recognize an impairment loss in an amount equal to that excess.”  As such, we believe
your accounting policy represents an “error in previously issued financial statements” that
should be corrected.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 March 22, 2023 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
March 22, 2023
Page 2
Revenue Recognition
Mining Pool Services, page F-24
2.We note your response to prior comment 3 in your March 1, 2023 letter, which you
provided to clarify your response to comment 9 in your December 30, 2022 letter.  Please
tell us the following:
•Such responses appear to indicate that you have concluded under ASC 606, step 2
that you have a single promise – to validate a block – and therefore a single
performance obligation.  Please confirm whether our understanding is correct.
•Such responses also appear to indicate that you believe under ASC 606-10-25-4 a
contract is wholly unperformed until you validate a block.  Please confirm whether
our understanding is correct.  If our understanding is correct, please revise the ASC
606-10-25-4 analysis provided in your December 30, 2022 response to comment 9 to
clarify, if true, that you have concluded computing power is not a good or service you
promised to provide under your contract.  Also clarify what the phrase “transaction
verification services” refers to in that response as the sentence that references it also
refers to computing power and to validating a block.
•Such responses further appear to indicate that you have concluded that a contract both
commences and is completed when you validate a block.  Please confirm whether our
understanding is correct.
3.As the preceding comment indicates, we continue to evaluate your conclusions related to
contract inception and contract duration. However, we believe that your accounting policy
to measure noncash consideration at a point other than contract inception does not comply
with ASC 606-10-32-21 and should be corrected.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yi Gao