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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

July 25, 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, 2022

Filed April 17, 2023

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 July 11, 2023 (the “July 11 Comment Letter”) relating to the Company’s annual report on Form 20-F for the
fiscal year ended December 31, 2022 filed with the Commission on April 17, 2023 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the July 11 Comment Letter. The Staff’s comments are retyped below in bold italic font for your
ease of reference. The Company respectfully advises the Staff that where the Company proposes to add or revise disclosure in its future
annual reports on Form 20-F in response to the Staff’s comments, the changes to be made will be subject to relevant factual updates
and changes in relevant laws or regulations, or in interpretations thereof.

    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

    July 25, 2023
    -2-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December
31, 2022

Item 3. Key Information, page 5

 1. Please revise here to include the proposed disclosures provided in paragraph 1 of the response to comment 3 in your December
30, 2022 letter.

In response to the Staff’s comment, in the Company’s future
annual reports on Form 20-F, the Company will revise on or about page 5 of “Item 3. Key Information” to include an updated
version of the proposed disclosures provided in paragraph 1 of the response to comment 3 in its December 30, 2022 response letter, consistent
with the changes set forth in Annex A.

Cash Flows through our Organization, page 6

 2. Please revise to include the proposed disclosures provided in comment
2 of your December 30, 2022 response letter. In this regard, quantify and discuss any cash flows and transfers of other assets by type
that have occurred between the holding company and its subsidiaries, and the direction of transfer including their tax consequences, if
any, for each period presented.

In response to the Staff’s comment, in the Company’s future
annual reports on Form 20-F, the Company will revise on or about page 6 under “Cash Flows through our Organization” to include
an updated version of the proposed disclosures provided in comment 2 of its December 30, 2022 response letter, consistent with the changes
set forth in Annex A.

The Company has supplemented such proposed disclosures to quantify
and discuss any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries,
and the direction of transfer including their tax consequences for each period presented. The Company respectfully advises the Staff that
since the Company disposed of its VIE structure by the end of 2021, there is no such VIE-related data available for 2022.

Holding Company Structure, page 6

 3. Please revise to improve legibility by increasing the font size of the text in your organization chart here and on page 58.

In response to the Staff’s
comment, in the Company’s future annual reports on Form 20-F, the Company will revise to improve legibility by increasing the
font size of the text in its organization chart on or about page 6 under “Holding Company Structure” and on or about
page 58. The proposed revised chart is set forth in Annex A.

    Simpson Thacher & Bartlett

    July 25, 2023
    -3-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

Item 5. Operating and Financial Review
and Prospects Results of Operations The year ended December 31, 2021 compared with the year ended December 31, 2020, page
67

 4. Please revise to discuss the reasons for the negative profit margins in your mining pool segment as disclosed in Note 24 and
explain whether you anticipate this trend to continue in future periods. We refer to comment 11 in your September 6, 2022 response letter.

In response to the Staff’s comment, in the Company’s future
filings, the Company will revise to discuss the reasons for the negative profit margins in its mining pool segment as disclosed in Note
24 and explain whether it anticipates this trend to continue in future periods. The proposed disclosures on or about page 65 are set forth
below.

The year ended December 31, 2022
compared with the year ended December 31, 2021

Revenues

 For the year ended December 31, 2022, revenues were mainly
comprised of revenues after inter-segment elimination from the mining pool business of US$593.2 million, the cryptocurrency mining business
of US$46.8 million and the data center business of US$10.0 million. For the year ended December 31, 2021, revenues were mainly comprised
of revenues after inter-segment elimination from the mining pool business of US$1,275.1 million, the cryptocurrency mining business of
US$39.4 million, and the data center business of US$11.8 million.

Operating cost and expenses

 Cost
of revenue. For the year ended December 31, 2022, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$600.7 million, the cryptocurrency mining business of US$42.0 million and the data center
business of US$14.2 million. For the year ended December 31, 2021, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$1,283.9 million, the cryptocurrency mining business of US$23.8 million, and the data center
business of US$14.3 million.

    Simpson Thacher & Bartlett

    July 25, 2023
    -4-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The gross losses for the years ended December 31, 2022 and 2021 were
US$7.5 million and US$8.8 million for the mining pool business, and US$4.2 million and US$2.4 million for the data center business. The
gross profits for the years ended December 31, 2022 and 2021 were US$4.9 million and US$15.6 million for the cryptocurrency mining business.

Regarding the mining pool business, for the year ended December
31, 2022, US$492.2 million revenues included in the revenue from mining pool segment were recognized from primary mining pool services.
Such revenues include block rewards and transaction verification fees from successful block placements. The Company also generates revenues
from sub mining pool services, where the Company contributes a portion of the computing power it obtained from BTC.com pool participants
to the third-party mining pool operators. In exchange, the Company is entitled to considerations in the form of cryptocurrencies from
the third-party mining pool operators calculated based on a predetermined formula regardless of whether the third-party mining pool operators
successfully validate the blocks. For the year ended December 31, 2021, the entire revenues included in the revenue from mining pool segment
were recognized from primary mining pool services. Cost of mining pool services primarily consists of mining rewards allocated to each
pool participant in exchange for their computing power contributed to the mining pool.

For primary mining pool services, the Company receives from
the blockchain the actual block rewards and distributes to the Company’s mining pool participants based on expected block rewards.
In other words, under the sharing mechanisms adopted by the Company for its primary mining pool services, the mining pool participants
are entitled to the compensation regardless of whether the Company successfully records a block. Such variability when the actual block
rewards are different from the expected block rewards within the mining pool is referred as the lucky index. The negative profit margin
in the mining pool segment was mainly caused by fluctuation in the lucky index. During certain periods in 2021 and 2022, the primary mining
pool services had a lucky index below 100% and had to distribute more block rewards to the mining pool participants than the actual blocks
it received. The fluctuation in lucky index is largely a result of the randomness and uncertainty inherent in the primary mining pool
services. As such, for primary mining pool services, the Company is unable to predict whether this trend would continue in future periods.

In order to mitigate the impact of fluctuation in the lucky
index, during 2022, the Company entered into the sub mining pool services. As the Company is entitled to considerations from the third-party
mining pool operators regardless of whether the third-party mining pool operators successfully validate the blocks, the Company generated
positive gross margin from sub mining pool services during the year ended December 31, 2022. The Company expects to maintain its cooperation
with the third-party mining pool operators, as a result, the Company does not expect negative profit margins from its sub mining pool
services in future periods. However, the Company is unable to predict the trend for its overall mining pool segment.

With regards to the cryptocurrency mining business, the gross
profits are largely driven by the cryptocurrency prices.

For the data center business, revenues are generated from
providing its customers with rack space, utility, and cloud services such as virtual services, virtual storage, and data backup services.
Cost of revenue is primarily comprised of direct production cost related to data center service as well as depreciation and amortization
of the data centers. The gross losses of data center business for the year ended December 31, 2022 were mainly attributable to continuous
declines in cryptocurrency prices since the second quarter of 2022, which led its customers to suspend their cryptocurrency mining operations,
resulting in fewer revenues generated. The gross losses of data center business for the year ended December 31, 2021 were mainly due to
the closure and demolition of data centers in Sichuan, China in June 2021, and the depreciation and amortization costs related to the
construction of Ohio data center since October 2021 while the revenues generated from such date center during the year ended December
31, 2021 were limited. Due to the fluctuation in cryptocurrency prices, the Company is unable to predict whether the negative gross margin
of the data center business would continue in future periods.

    Simpson Thacher & Bartlett

    July 25, 2023
    -5-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The year ended December 31, 2021
compared with the year ended December 31, 2020

Operating cost and expenses

Cost
of revenue.  For the year ended December 31, 2021, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$1,283.9 million, the cryptocurrency mining business of US$23.8 million and the data center
business of US$14.3 million. The respective gross loss was US$8.8 million for the mining pool business, US$2.4 million for the data center
business, and gross profit of US$15.6 million for the cryptocurrency mining business. Please refer to above for discussion of the reasons
for the negative gross margin of the mining pool business and the data center business. There were no operations of the mining pool business,
the cryptocurrency mining business or the data center business in 2020.

Note 2. Summary of Significant Accounting Policies

Mining Pool Services, page F-25

 5. As noted in our prior comment 3, we continue to evaluate your conclusions related to contract inception and contract duration
as per your response to comment 3 in your March 1, 2023 letter.

The Company respectfully acknowledges the
Staff’s comment.

Sub Mining Pool Services, page F-26

 6. So that we may better understand your accounting policy for sub mining pool services, please address the following:

 · Explain further the nature of these sub mining pool arrangements with third-party pool operators.

 · Clarify how these arrangements "stabilize the mining rewards" that the Group is entitled to.

 · Provide us your analysis as to how you determined you are the principal such that revenue should be recognized gross in these
arrangements. Refer to ASC 606-10-55-36 to 55-40.

 · Clarify whether you are deemed the mining pool participant in the arrangement with the third party mining pool operator.

 · Describe in detail your rationale for classifying these revenues as mining pool revenues as opposed to cryptocurrency mining
revenues.

    Simpson Thacher & Bartlett

    July 25, 2023
    -6-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The Company respectfully advises the Staff
the following:

 · The Company entered into arrangements with two third-party mining pool operators
and essentially became the mining pool participants of the third-party mining pools. Below is a summary of material rights and obligations
of these arrangements with the third-party pool operators:

Mining pool participant (the Company):

 i. Can shut down account at any time.

 ii. Right to monitor the mining status by receiving real-time mining hashrates, and mining earnings.

Mining pool operators (third-party mining pools):

 i. Provide billing statement to mining pool participants on a daily basis.

 ii. Determine and distribute mining rewards to mining pool participants using the FPPS (Full Pay-Per-Share) sharing mechanism. (Refer
to section below for further information on the FPPS sharing mechanism.)

 iii. Have the right to charge fees for mining pool services based on the specific fee rate published or otherwise agreed by both parties.

 iv. Have the right to make a unilateral determination to process or terminate providing services considering the results of unilateral
determination.

Based on the material rights and obligations summarized
above, the Company collects the computing power contributed by the Company’s individual mining pool participants in the BTC.com
mining pool and delivers such computing power to the third-party mining pool operators. In exchange, the Company is entitled to considerations
in the form of cryptocurrencies from the third-party mining pools calculated based on a predetermined formula regardless of whether the
third-party mining pool operators successfully validate the blocks. The Company receives the mining rewards distributed from the third-party
mining pool operators in the following day of providing the computing power and would also distribute the mining rewards to each of its
pool participant based on the predetermined formula on the same day. The rewards r