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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

 April 12, 2023

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 March 22, 2023 (the “March 22 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 March 22 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

April 12, 2023 -2- Division of Corporation Finance

U.S. Securities and Exchange Commission

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.

The
Company respectfully acknowledges the Staff’s comment and has evaluated the materiality of the error from qualitative
and quantitative perspectives in accordance with Staff Accounting Bulletin (“SAB”) 99, Materiality, and SAB
108, Considering the Effects of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial
Statements. Based on the evaluation, the error is not material to the previously issued financial statements. The Company
decided to correct the error prospectively by revising the previously issued financial statements and include disclosures in its
annual report on Form 20-F for the year ended December 31, 2022 as follows:

Revision of Previously Issued
Financial Statements

During the preparation of this Annual
Report, the Company identified and corrected an immaterial error related to the impairment calculation of cryptocurrency assets. The
Company has been historically calculating the impairment of cryptocurrency assets on a daily basis using a spot price at a standard cutoff
time. The Company determined such a method was not in compliance with ASC 350-30-35-19 which requires the recognition of impairment when
carrying value exceeds fair value. The Company further determined that the intraday lowest quoted price should be utilized in calculating
impairment of the Company’s cryptocurrency assets.

In
accordance with Staff Accounting Bulletin (“SAB”) 99, Materiality, and SAB 108, Considering the Effects
of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial Statements, the Company evaluated the materiality
of the error from qualitative and quantitative perspectives, and concluded that the error was immaterial to the Consolidated
Balance Sheet as of December 31, 2021 and Consolidated Statement of Comprehensive Loss, Changes in Shareholders’ Equity and
Cash Flows for the year ended December 31, 2021. The following tables present the impact of this error on the Company’s financial
statements as of December 31, 2021 and for the year ended December 31, 2021:

Simpson Thacher & Bartlett

April 12, 2023 -3- Division of Corporation Finance

U.S. Securities and Exchange Commission

    As of December 31, 2021

    Consolidated Balance Sheet

 Amounts in thousands U.S. dollars (“US$”)

    As Reported
    Effect of

Adjustment
    As Revised

    Cryptocurrency assets
    $ 55,077
    $ (1,887 )
    $ 53,190

    Total current assets
      95,143
      (1,887 )
      93,256

    Total assets
      296,116
      (1,887 )
      294,229

    Accumulated deficit and statutory reserve
      (384,867 )
      (1,887 )
      (386,754 )

    Total shareholders' equity
      207,150
      (1,887 )
      205,263

    Total liabilities and shareholders' equity
      296,116
      (1,887 )
      294,229

    For the year ended December 31, 2021

    Consolidated Statement of Comprehensive Loss

 Amounts in thousands of U.S. dollars (“US$”), except for number of shares and per share (or ADS) data

    As Reported
    Effect of

Adjustment
    As Revised

    Net gain on disposal of cryptocurrency assets
    $ 6,717
    $ 4,675
    $ 11,392

    Impairment of cryptocurrency assets
      (31,757 )
      (6,562 )
      (38,319 )

    Operating loss from continuing operations
      (68,350 )
      (1,887 )
      (70,237 )

    Loss before income tax from continuing operations
      (63,925 )
      (1,887 )
      (65,812 )

    Net loss from continuing operations
      (63,566 )
      (1,887 )
      (65,453 )

    Net loss
      (72,487 )
      (1,887 )
      (74,374 )

    Net loss attributable to BIT Mining Limited
      (60,516 )
      (1,887 )
      (62,403 )

    Losses per share for Class A and Class B ordinary shares outstanding-Basic and Diluted:

    Net loss from continuing operations
      (0.08 )
      (0.01 )
      (0.09 )

    Net loss
      (0.09 )
      (0.01 )
      (0.10 )

    Losses per American Depositary Share ("ADS*") (1 ADS represents 100 Class A ordinary shares)-Basic and Diluted:

    Net loss from continuing operations
      (8.32 )
      (0.30 )
      (8.62 )

    Net loss
      (9.72 )
      (0.30 )
      (10.02 )

* American Depositary Shares, which are traded
on the NYSE. Each ADS represents one hundred Class A ordinary shares of the Company.

Note: Losses per ADS have been retrospectively
adjusted for the ADS Ratio Change from the former ADS Ratio of 1 ADS to 10 Class A ordinary shares, to the current ADS Ratio of
1 ADS to 100 Class A ordinary shares, effective on December 23, 2022.

Simpson Thacher & Bartlett

April 12, 2023 -4- Division of Corporation Finance

U.S. Securities and Exchange Commission

    For the year ended December 31, 2021

    Consolidated Statement of Cash Flows

 Amounts in thousands U.S. dollars (“US$”)

    As Reported
    Effect of

Adjustment
    As Revised

    Net loss
    $ (72,487 )
    $ (1,887 )
    $ (74,374 )

    Impairment of cryptocurrency assets
      31,757
      6,562
      38,319

    Net gain on disposal of cryptocurrency assets
      (6,717 )
      (4,675 )
      (11,392 )

    For the year ended December 31, 2021

    Consolidated Statement of Changes in Shareholders' Equity

 Amounts in thousands U.S. dollars (“US$”)

    Accumulated
    deficit
 and statutory reserve
    Total shareholders'

 equity

    Net loss for the year (as reported)
    $ (60,516 )
    $ (72,487 )

    Net loss for the year (effect of adjustment)
      (1,887 )
      (1,887 )

    Net loss for the year (as revised)
      (62,403 )
      (74,374 )

    Balance as of December 31, 2021 (as reported)
      (384,867 )
      207,150

    Balance as of December 31, 2021 (effect of adjustment)
      (1,887 )
      (1,887 )

    Balance as of December 31, 2021 (as revised)
      (386,754 )
      205,263

The Company also proposes to revise
and include the following accounting policy on cryptocurrency assets in its future filings:

“Cryptocurrencies held are accounted
for as intangible assets with indefinite useful lives. An intangible asset with an indefinite useful life is not amortized but assessed
for impairment quarterly, or more frequently, when events or changes in circumstances occur, principally decreases in the quoted prices
of the cryptocurrencies, indicating that it is more likely than not that the indefinite-lived asset is impaired. In determining if an
impairment has occurred, the Company considers the intraday lowest quoted price of one unit of cryptocurrency asset since acquiring the
cryptocurrency asset. If the then current carrying value of the unit of cryptocurrency exceeds the fair value so determined, an impairment
loss has occurred with respect to those units of cryptocurrencies in the amount equal to the difference between their carrying values
and the fair value determined. To the extent an impairment loss is recognized, the loss establishes the new cost basis of the asset.
Subsequent reversal of impairment losses is not permitted.”

Simpson Thacher & Bartlett

April 12, 2023 -5- Division of Corporation Finance

U.S. Securities and Exchange Commission

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.

  The Company respectfully submits the following:

 • The Company confirms that it has concluded that under ASC 606, step
2 that the mining pool service arrangement has a single promise, which is to validate a block, and therefore a single performance obligation.

 • The Company confirms that it has concluded that under ASC 606-10-25-4
a contract is wholly unperformed until a block is validated. The Company revises the ASC 606-10-25-4 analysis provided in December 30,
2022 response to comment 9 with respect to the following paragraph:

Simpson Thacher & Bartlett

April 12, 2023 -6- Division of Corporation Finance

U.S. Securities and Exchange Commission

“The Company has considered ASC 606-10-25-4 and concluded
that a contract does not exist upon the Company initially providing computing power to the blockchain to solve an algorithm because upon
commencing the transaction validation service and before successfully verifying a block (that is, before the transfer of the promised
performance obligation which is a successful block validation), the Company still has the unilateral right to terminate the service without
compensating the blockchain.”

The above paragraph should be revised as follows:

“The
Company has considered ASC 606-10-25-4 and concluded that a contract does not exist upon the Company initially providing computing power
to the blockchain to solve an algorithm because upon providing the computing power and before successfully verifying a block (that is,
before the transfer of the promised performance obligation which is a successful block validation), the Company still has the unilateral
right to terminate the service without compensating the blockchain. Computing power is not a good or service the Company
promised to provide under the arrangement with the blockchain. Instead, transaction verification service, or the service to validate
blocks, is the promised service under the arrangement.”

 • The Company confirms that it has concluded that a contract both commences
and is completed when the Company validates a block.

 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.

The Company respectfully acknowledges the Staff’s
comment.

With regard to the measurement of
the noncash considerations in the mining pool service arrangements, the Company has carefully evaluated the Staff comment and
determined that its current practice to measure noncash consideration at a point other than contract inception does not comply with
ASC 606-10-32-21. Based on a recalculation of the fair value of noncash considerations at contract inception, the Company determined
that the error is both quantitatively and qualitatively immaterial to the financial statements for the year ended December 31,
2021.

The Company has corrected the error in accounting policy by measuring the noncash considerations at contract inception for the year ended
December 31, 2022. Furthermore, the Company decided not to revise the 2021 financial statements when filing its annual report on Form
20-F for the year ended December 31, 2022 because the error does not impact the consol