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    Simpson
                    Thacher & Bartlett

    icbc
    tower, 35th floor

    3
    garden road, central

    hong
    kong

    telephone:
                    +852-2514-7600

    facsimile:
    +852-2869-7694

    Direct
                                            Dial Number

    +852-2514-7620

    E-mail
                                            Address

    ygao@stblaw.com

    December 30, 2022

    CONFIDENTIAL AND VIA EDGAR

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Attention:
    Ms. Kathleen Collins

    Ms. Megan Akst

 Re: BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed April 7, 2022

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated November 15, 2022 (the “November 15 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2021 filed with the Commission on April 7, 2022 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the November 15 Comment Letter. The Staff’s comments are retyped below in bold italic font for
your ease of reference.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
      ADAM
    S. GOLDBERG
      MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    kathryn
    kING  sudol
    christopher
    k.s. wong

resident
partners

simpson
thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

     Simpson Thacher & Bartlett

December 30, 2022 -2-  Division of Corporation Finance

U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December
31, 2021

Item 3. Key Information, page 3

 1. We note your response to prior comment 2. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment to your current Form 20-F.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“BIT Mining Limited, our ultimate Cayman
Islands holding company, does not have substantive operations other than (1) holding certain of our digital assets in connection with
our cryptocurrency mining business and (2) indirectly holding the equity interest in our subsidiaries in Hong Kong, British Virgin Islands,
Canada, Malta, Cyprus, Curacao, Kazakhstan, the United States and China. As of the date of this annual report, (i) we do not have revenue-generating
operations in China, and our remaining operations in China primarily involve the provision of administrative support to our cryptocurrency
mining business as well as the provision of internal information technology services to our operating entities and mining pools outside
China; and (ii) we do not maintain any variable interest entity structure in China. Adverse actions by the Chinese government may potentially
force us to cease our administrative support and internal information technology services from China to your international cryptocurrency
mining business. We have developed Ethereum mining operation in Hong Kong, but have no plan to further expand such Hong Kong-based operation.
This is because we are focusing on growing our cryptocurrency mining operations in the United States. In 2019, 2020 and 2021, our operations
in Hong Kong generated approximately nil, nil and 1.4% of our total revenue for such year. As used in this annual report, “we,”
 “us,” “our company” or “our” refers to BIT Mining Limited, a Cayman Islands exempted company and its
subsidiaries. Investors in our ADSs are purchasing equity interest in a Cayman Islands holding company.

“The following diagram illustrates
our company’s organizational structure, and the place of formation, ownership interest and affiliation of each of our principal
subsidiaries and affiliated entities as of the date of this annual report. BIT Mining Limited, in which investors hold an interest, is
shared in grey.”

 2. We note your response to prior comment 3. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“Cash can be transferred between our
holding company in Cayman Islands and our subsidiaries in China and other regions and countries through intercompany fund advances and
capital contributions.

     Simpson Thacher & Bartlett

December 30, 2022 -3-  Division of Corporation Finance

U.S. Securities and Exchange Commission

“As of the date of this annual report,
BIT Mining Limited has not distributed any earnings to its subsidiaries or the former VIEs. BIT Mining Limited currently does not have
any plan to distribute earnings to our subsidiaries in the foreseeable future. No transfers, dividends, or distributions have been made
to date to U.S. investors.

“In 2019, 2020 and 2021, BIT Mining
Limited transferred cash to our subsidiaries of RMB9.4 million, nil and RMB426.1 million, respectively, through intercompany fund advances
and capital contributions. BIT Mining Limited transferred cash to the former VIEs of RMB56.8 million, RMB27.9 million and RMB8.8 million,
respectively, through intercompany fund advances and long-term loan, which was interest free and without recourse. Our wholly-owned subsidiaries
in China transferred cash to the former VIEs of RMB102.7 million, RMB10,000 and RMB2.8 million, respectively, through short-term loan,
which was interest free and without recourse. Furthermore, in 2021 and up to the date of this annual report, our subsidiaries in China
transferred certain cryptocurrency mining assets and equipment to our overseas subsidiaries, which was a part of our business strategy
to migrate our cryptocurrency mining business out of China.

“In 2019, 2020 and 2021, the former
VIEs transferred cash to our wholly-owned subsidiaries of RMB2.8 million, RMB8.3 million and RMB186.9 million, respectively, pursuant
to our former contractual arrangements.

“The aforementioned cash and assets
transfers among our Cayman holding company, subsidiaries and the former VIEs were for business operation purposes. As of the date of this
annual report, a substantial majority of our assets and cash are located outside of China. We are not aware of any regulatory restrictions
of transferring funds between our Cayman Islands holding company and subsidiaries in Hong Kong, British Virgin Islands, Canada, Malta,
Cyprus, Curacao, Kazakhstan and the United States. We are subject to applicable PRC regulation of loans to or investment in subsidiaries
in China.”

 3. We note your response to prior comment 4. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“We face various legal and operational
risks and regulatory uncertainties associated with having certain non revenue-generating subsidiaries, certain administrative personnel,
and certain members of the board of directors located in China. The PRC government has significant authority to exert influence on the
ability of a company located in China to conduct its business, accept foreign investments or list on U.S. or other foreign exchanges.
We cannot assure you that such influence will not be extended to companies operating in Hong Kong, such as our Hong Kong subsidiaries.
We may have to scale down or cease our remaining operations in China and our Ethereum mining operation in Hong Kong, if the PRC government
extends its influence and/or control in Hong Kong to restrict or otherwise regulate our remaining operations in China and our Ethereum
mining operation in Hong Kong. For example, we face risks and uncertainties associated with regulatory approvals of offshore offerings
and oversight on cybersecurity and data privacy. Such risks and uncertainties could
result in a material change in our operations and/or the value of the ADSs or could significantly limit or completely hinder our ability
to offer ADSs and/or other securities to investors and cause the value of such securities to significantly decline or be worthless. The
PRC government also has significant discretion over our business operations in China, and may intervene with or influence our China-based
operations as it deems appropriate to further regulatory, political and societal goals. Furthermore, the PRC government has recently indicated
an intent to exert more oversight and control over overseas securities offerings and foreign investments in China-based companies. These
regulatory risks and uncertainties could become applicable to our Hong Kong operations if regulatory authorities in Hong Kong adopt similar
rules and/or regulatory actions. Any adverse action, once taken by the PRC and/or Hong Kong government, could significantly limit or completely
hinder our ability to offer securities to investors and cause the value of such securities to significantly decline or in extreme cases,
become worthless.

     Simpson Thacher & Bartlett

December 30, 2022 -4-  Division of Corporation Finance

U.S. Securities and Exchange Commission

“Our U.S.-based auditor, MaloneBailey,
LLP, is not among the PCAOB-registered public accounting firms headquartered in the PRC or Hong Kong that are subject to PCAOB’s
determination on December 16, 2021 of having been unable to inspect or investigate completely. As of the date of this annual report, we
have not been identified by the SEC as a commission-identified issuer under the Holding Foreign Companies Accountable Act (“HFCA
Act”). However, we could still face the risk of delisting and cease of trading of our securities from a stock exchange or an over-the-counter
market in the United States under the HFCA Act and the securities regulations promulgated thereunder if the PCAOB determines in the future
that it is unable to completely inspect or investigate our auditor which has a presence in China.”

Item 8. Financial Information

Note 2. Summary of Significant Accounting Policies, page F-15

 4. We note your response to prior comment 13. Please tell us how you considered the guidance in ASC 350-10-40-1 in determining
that transactions involving the payment of expenses or the acquisition of assets in exchange for cryptocurrency should be accounted for
in accordance with ASC 845. Also, tell us how you determined that no gain or loss is recognized in such transactions and specifically
address situations in which the fair value of the cryptocurrency exchanged exceeded the carrying value. Lastly, revise your proposed accounting
policy to eliminate the reference to "generally" and describe the circumstance in which the transfer would not be based on fair
value or revise as necessary.

The Company respectfully acknowledges the
Staff’s comment and has reassessed the accounting for transactions involving the payment of expenses or the acquisition of assets
in exchange for cryptocurrency as follows.

The Company has considered ASC 350-10-40-1
which indicates that an entity shall account for the derecognition of a nonfinancial asset in accordance with ASC 610-20 unless a scope
exception from ASC 610-20 applies. Based on ASC 610-20-15-4, the scope exception includes nonmonetary transactions within the scope of
ASC 845. The Company has further analyzed under ASC 845-10-15-4 that the transfer of a nonfinancial asset within the scope of ASC 610-20
in exchange for noncash consideration would be scoped out from ASC 845. As a result, the Company concluded that transactions involving
the payment of expenses or the acquisition of assets in exchange for cryptocurrency should be accounted for under ASC 610-20.

     Simpson Thacher & Bartlett

December 30, 2022 -5-  Division of Corporation Finance

U.S. Securities and Exchange Commission

Pursuant to ASC 610-20, as the Company
does not hold controlling financial interests in any of the counterparties in the transactions, it evaluates the transactions in accordance
with ASC 610-20-25-5 through 25-7. The Company has concluded that contracts that meet all of the criteria in ASC 606-10-25-1 exist, and
the counterparties have obtained control of the cryptocurrencies. Therefore, in those transactions, the Company has met the criteria to
derecognize the cryptocurrencies. In accordance with ASC 610-20-32-2 through 32-3, the Company should recognize a gain or loss for the
difference between the amount of consideration measured and allocated to that asset and the carrying amount of the distinct asset. The
amount of consideration includes both the transaction price to be determined following ASC 606-10-32-2 through 32-27 and the carrying
amount of liabilities assumed or relieved by a counterparty.

The Company respectfully advises the Staff
that the nature of the Company’s transactions is mainly the transfers of USDT to pay off hosting expenses charged by third-party
mining data centers which host the Company’s mining machines and to acquire certain intangible asset. The relevant contracts were
priced in fiat currencies and the counterparties accepted the payments in the form of USDT. For these transactions, as the nature of the
transfer of cryptocurrencies is to settle existing liabilities, the amount of consideration is the carrying amount of liabilities relieved
by the counterparties in accordance with ASC 610-20-32-5.

As the value of USDT pegs to US dollar
and is relatively stable, the carrying amount of the USDT transferred approximates the amount of consideration. Therefore, the Company
did not record any gain or loss on such transactions. The reassessed accounting treatment has no impact to the financial statements.

The Company proposes to add the following
revised disclosure under the accounting policy of cryptocurrency assets.

“Cryptocurrency assets

The Company also enters into transactions
to transfer cryptocurrencies to pay for operating expense and to acquire certain assets. Such transactions are accounted for in accordance
with ASC 610-20, “Other Income - Gains and Losses from the Derecognition of Nonfinancial Assets”. Under ASC 610-20, if the
Group does not have a controlling financial interest in the entity that holds the cryptocurrency and the arrangement meets the criteria
to be accounted for as a contract, the Group would de-recognize the cryptocurrency and recognize a gain or loss on the transfer of the
cryptocurrency when control of the cryptocurrency transfers to the counterparty. The gain or loss is measured as the difference between
the amount of consideration allocated to the cryptocurrency and its carrying amount. For the year ended December 31, 2021, the gain or
loss recorded on such transactions was nil.”

Cryptocurrency Assets, page F-18

 5. Your response to prior comment 14 appears to make conflicting representations. In this regard, you state that you recognize
impairment "whenever the car