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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

August 31, 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 August 17, 2023 (the “August 17 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 August 17 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.

Simpson Thacher & Bartlett

August 31, 2023 -2- Division of Corporation Finance

U.S. Securities and Exchange Commission

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

Item 5. Operating and Financial Review Prospects Results of Operations

The year ended December 31, 2022 compared with the year ended December 31, 2021, page 65

    1.
    We note your proposed revised disclosures in response to prior comment 4. Please revise to separately discuss and quantify the revenue and cost of revenue from each of the primary and sub mining pool services so to better clarify the potential significant disparity in gross profit for each.

In response to the Staff’s comment, in the Company’s
future filings, the Company will revise to separately discuss and quantify the revenue and cost of revenue from each of the primary and
sub mining pool services and to discuss the reasons for the gross profit or gross loss for each. The proposed revised disclosures are
set forth in Annex A.

Sub Mining Pool Services, page F-26

    2.
    Please address further the following as it relates to your response to prior comment 6.

    ·
    Describe, in detail, how the technology and process work such that you both transfer computing power generated by your mine pool participants to the mining pools in which you participate and control the computing power of your mining pool participants before you transfer it to the mining pool operators of the mining pools in which you participate. For example, are you relaying the block header, the block version, and the block data provided by the mine pool operator of the mine pool in which you participate as well as your wallet address to the participants in your mining pool?

    ·
    Specify the terms of your Agreements that provide the company with control over the service of providing computing power before it is provided to the third-party pool operators and the ability to transfer such service.

    ·
    Highlight any significant differences between the rights and obligations of your mine pool participants and your rights and obligations in the mining pools in which you participate. As part of that comparison, compare the payout mechanism of the pool you operate with the pools with which you participate, identifying each significant variable effecting both the block reward and transaction fee components of those payouts.

    ·
    Explain to us how you receive payouts from the third-party pools in which you participate, including whether you provide your wallet address to the third-party operator. In this regard, clarify whether rewards are received in BTC.com's wallet and then distributed to your mining pool participants' wallets.

    ·
    Summarize the material terms of, and provide us with a copy of, the Specific Service Agreement that is referenced in the BTC.com User Agreement. Also, identify the mining pools in which you participate and provide us with a copy of the agreements that specify the rights and obligations of the parties to those agreements.

Simpson Thacher & Bartlett

August 31, 2023 -3- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    Provide a comprehensive accounting analysis of how you determined that you control the computing power of the mining pool participant before it is provided to third-party pool operators. Refer to ASC 606-10-25-25.

The Company respectfully advises the Staff the following:

    ·
    For sub mining pool services, the Company decided to contribute all the computing power it obtained from BTC.com pool participants for mining bitcoins to the third-party mining pool operators. For mining of other types of cryptocurrencies in the BTC.com mining pool, the Company still provides primary mining pool services.

With respect to the technology and processes of the sub
mining pool services, the entire user registration and miner configuration processes remained the same as the processes before the Company
entered into the sub mining pool services, nor did the mining IP addresses change. The Company continues to display real-time hash rate
and expected mining profits information on its pool participants’ account dashboard. Before and after the Company entered into the
sub mining pool services, the BTC.com pool participants would not be able to tell any differences in terms of their mining experiences.
Upon the BTC.com pool participants connecting their mining equipment by configuring the equipment with the mining IP addresses provided
by BTC.com, the computing power would flow through the Company’s nodes and then be redirected to the third-party mining pool operators’
servers. The Company’s nodes are provided by Cloudflare, a third-party network service provider, for enhanced network security and
reliability. During the mining process, the Company’s nodes would relay the necessary information for mining, such as the block
header, the block version, and the block data provided by the third-party mine pool operators, to the BTC.com pool participants. The block
rewards and transaction verification fees attached to each block placement would be deposited directly into the third-party mining pools’
wallets. As a result, the third-party mining pools’ wallet addresses were included in the block information used for mining.

In the processes described above, the Company controls the
computing power of the BTC.com pool participants before it is transferred to the third-party mining pool operators because: 1) it is up
to the Company to decide the specific portion of computing power to be transferred to the third-party mining pool operators, without any
consent required from BTC.com pool participants; 2) the information flows through its nodes and the Company is responsible for transferring
accurate and timely block information to both the pool participants and the third-party mining pool operators.

Simpson Thacher & Bartlett

August 31, 2023 -4- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    As the BTC.com mining pool operator, the Company and its pool participants entered into arrangements governed by the standard agreements on the website of BTC.com (BTC.com Pool Service Agreement1 and BTC.com User Agreement2). The aforementioned agreements are attached hereto as Annex C. In addition, there are some statements and FAQs made by BTC.com on its website and other customary business practices that together form the contract between BTC.com and its pool participants. The Company believes the following terms in the contract would provide the Company with control over the computing power before it is provided to the third-party pool operators and the ability to transfer such computing power:

    1)
    Section 6.1 of the BTC.com User Agreement specifies that “you agree that we reserve the right to limit, change, suspend or even terminate all or part of the Services at any time”.

    2)
    Section 8.2 of the BTC.com User Agreement specifies that “this agreement is binding upon you and BTC.com, and it did not create any third-party beneficiary rights. You may not assign or transfer any of your rights or obligations under the Agreement without prior written consent from BTC.com. BTC.com may assign or transfer any or all of its rights and obligations under the Agreement, in whole or in part, without notice or obtaining your consent or approval”.

Based on the terms above, BTC.com has the right to direct
the use of the computing power and is able to transfer such computing power to other parties without notice or obtaining its pool participants’
consent or approval.

    ·
    The Company respectfully advises the Staff that there are no significant differences between the rights and obligations of the Company’s mining pool participants in the Company's BTC.com mining pool and the Company’s rights and obligations in the third-party mining pools in which the Company participates except for the pool operators’ fee rate charged by the pool operators, which will be explained in further details below. However, since the arrangements between the Company and the Company’s mining pool participants, and the arrangements between the Company and the third-party mining pool operators were entered into and executed separately, the rights and obligations of the aforementioned arrangements were not related and would not impact each other. In the case that the Company did not receive the payments from the third-party mining pools, it would still be obligated to calculate, allocate and distribute the earnings or mining rewards to the BTC.com mining pool participants based on predetermined sharing mechanism.

1Annex
C page C-2 to C-4. It can also be found at https://activity.btc.com/agreement/#/miningservice?lang=en.

2Annex
C page C-5 to C-9. It can also be found at https://activity.btc.com/agreement/#/user?lang=en.

Simpson Thacher & Bartlett

August 31, 2023 -5- Division of Corporation Finance

U.S. Securities and Exchange Commission

The payout mechanism in the Company’s mining pool
and that in the third-party mining pools are both FPPS (Full Pay-Per-Share). The only variable between the payout mechanism of the BTC.com
mining pool and that of the third-party mining pools is the rate of pool operator fee retained by the pool operators. For ease of reference,
the Company included the formula of FPPS in the table below.

    Sharing mechanism
    Reward for pool participant

    FPPS
    Expected block rewards1*(1+FPPS rate2)*Computation submitted by the participant /Whole blockchain workload*(1-Pool operator fee rate set up by mining pool)

1. Expected block rewards: expected new block rewards granted
by the blockchain network, taken the bitcoin network as an example, 6.25 bitcoins in every 10 minutes approximately in the current halving
cycle.

2. FPPS rate: prior day transaction fee earned within the pool
divided by prior day block rewards earned within the pool.

Under the FPPS payout mechanism, the expected block
rewards and transaction verification fees were paid out as a whole from the third-party mining pools to the Company, and from the
Company to the Company’s mining pool participants, respectively. The Company also receives from the third-party mining pools
and pays to its pool participants, elastos (“ELA”) and namecoins (“NMC”) as the bonus from mining bitcoins. The value of the two
bonus coins is immaterial. The Company respectfully advises the Staff that the pool operator fee rate set up by BTC.com for bitcoin
was 4%3. The pool operator fee rates set up by the
third-party mining pool operators in which the Company participates were lower due to discounts offered to larger pool
participants.

    ·
    The Company respectfully advises the Staff that the Company provides its wallet address to each of the two third-party mining pools in which the Company participates. On a daily basis, the third-party mining pools would distribute, and the Company would receive the mining rewards determined based on the aforementioned FPPS payout mechanism for providing computing power during the period from UTC 00:00 to UTC 23:59 of the previous day. The Company respectfully advises the Staff that the Company would usually receive the rewards statement from the third-party mining pools within one hour after UTC 0:00 every day and the third-party mining pools would initiate the payout soon after the rewards statement is made available. Depending on the time it takes the blockchain to confirm the transactions, the payouts from the third-party mining pools are usually received before UTC 8:00 every day. Once the rewards statements are received, the Company analyzes the data and calculates the corresponding mining rewards it should distribute to each pool participant based on the FPPS payout mechanism. The Company would usually distribute mining rewards to the Company’s mining pool participants between UTC 02:00 and UTC 06:00. The third-party mining pools do not calculate the mining rewards of each of the BTC.com pool participants, nor do they distribute the mining rewards directly to the BTC.com pool participants. In the situation where the Company receives mining rewards from the third-party mining pools prior to making mining rewards distribution to its mining pool participants, the rewards were received in BTC.com’s wallets first, then were distributed to the wallets of the Company’s mining pool participants. It happens that the Company might receive the mining rewards from the third-party mining pools later than it distributes the mining rewards to the pool participants. In this case, the Company would use its own bitcoin reserves in the wallets to make mining rewards distributions to its mining pool participants.

3 https://help.pool.btc.com/hc/en-us/articles/900001116943-The-fee-settlement-mode-and-payment-threshold-in-BTC-com-pool

Simpson Thacher & Bartlett

August 31, 2023 -6- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    The Company respectfully advises the Staff that the Specific Service Agreement referenced in the BTC.com User Agreement is the BTC.com Pool Service Agreement mentioned in the response to the second bullet point of comment 2. Please refer to below for a summary of material rights and obligations of each party in the aforementioned arrangement:

Mining pool participant (BTC.com pool participants):

    i.
    The pool participants are responsible for reviewing the latest version of the agreement in a timely manner. If the pool participants do not agree to the latest version of the agreement after any modification, they shall suspend registration for, or stop using the services provided by BTC.com.4

Mining pool operators (the Company):

    i.
    Have the right to make a unilateral determination to continue or terminate providing services to the users without their consent or prior notice.5

    ii.
    Reserves the right to switch the hashrate power to other currencies if problems of the mining currency itself may affect the mining output.6

4 BTC.com
Pool Service Agreement – 2nd paragraph

5 BTC.com
Pool Service Agreement Clause 2.2

6 BTC.com
Pool Service Agreement Clause 2.5

Simpson Thacher & Bartlett

August 31, 2023 -7- Division of Corporation Finance

U.S. Securities and Exchange Commission

The C