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 May 6, 2025

Erke Huang
Chief Financial Officer
Bit Digital, Inc
31 Hudson Yards, Floor 11
New York, NY 10001

 Re: Bit Digital, Inc
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-38421
Dear Erke Huang:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Digital Assets, page F-11

1. We note your determination of CoinMarketCap as your principal market for
valuing
 your digital assets. As CoinMarketCap is not a market where digital
assets can be
 traded but instead is a website where exchange/trading platform market
information is
 aggregated, its aggregated information cannot be the principal market,
or most
 advantageous market in the absence of a principal market, under ASC
820-10-35-5.
 As you trade with the Amber Group's OTC desk, please tell us your
consideration as
 to whether the OTC market is your principal market as contemplated in
ASC 820-10-
 35-5A. In your response, tell us how pricing is determined in the OTC
market and the
 extent to which information from CoinMarketCap or any other price
aggregator or
 index is utilized. Otherwise, tell us, for each material digital asset
you hold, which
 individual market is your principal or most advantageous market, how you
identified
 them, and whether use of these markets to value your digital assets
would result in a
 material difference from the financial statements presented in your
filing.
 May 6, 2025
Page 2

Note 3. Revenues From Contracts with Customers
Digital Asset Mining, page F-20

2. Please tell us, and revise your disclosure in future filings to
specifically address the
 following concerning your revenue recognition policy under ASC 606 for
mining
 bitcoin:
 Given that your mining pool contract can be terminated at any time by
either party
 without penalty, tell us whether you believe the contract is
continuously renewed,
 instead of renewed daily as you disclose. Refer to examples 1 and 2
of question 7
 and question 8 of the FASB Revenue Recognition Implementation Guide
Q&As.
 If so, tell us, and represent that you will revise your disclosure in
future filings to
 discuss:
 o Your consideration as to whether the duration of your contracts
is less than
 24 hours;
 o Whether the rate of payment remains the same upon renewal; and
 o Whether your customer s option to renew represents a material
right that
 represents a separate performance obligation as contemplated in
ASC 606-
 10-55-42.
 Your policy disclosure that you measure bitcoin mined on the date
received and
 that it is not materially different than valuing at contract
inception is inconsistent
 with the guidance you highlight in ASC 606-10-32-21. As a result,
please address
 the following:
 o Tell us, and represent to us that you will disclose in future
filings, the time
 period over which the mining pool operator calculates the
bitcoin
 consideration due you. This period often is daily from 00:00:00
UTC to
 23:59:59 UTC.
 o Represent to us, if true, that the difference between the fair
value used to
 record revenue on the date of receipt as compared to a time
consistently
 applied on the day before receipt (i.e., the date of contract
inception
 consistent with the requirement in ASC 606-10-32-21) is
immaterial in all
 periods presented in your filing.
 o Revise your practice going forward to value your bitcoin mined
at the fair
 value at a consistent time on the date of contract inception.
 o Represent to us that in future filings you will:
 disclose the specific consistent time chosen to value
bitcoin mined on the
 date of contract inception;
 remove reference to recording bitcoin mined at the time
of receipt and
 that it is not materially different than at contract
inception; and
 disclose that you recognize revenue on the same day that
control of the
 contracted service transfers to the mining pool
operators, which is the
 same day as contract inception.
 May 6, 2025
Page 3
Note 17. Segment Reporting, page F-41

3. Please tell us, and represent to us that you will revise future filings
to disclosure the
 following regarding your segments:
 the titles of the "several members of [y]our executive management
team" who
 comprise your CODM as required by ASC280-10-50-21c;
 a measure of profit or loss for each reportable segment and all of
the individual
 line items included in ASC 280-10-22 (a) - (j); and
 your entity-wide information concerning long-lived assets by
geographic area.
 Refer to ASC 280-10-50-41.

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact David Irving at 202-551-3321 or Mark Brunhofer at
202-551-3638
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
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