SecProbe.io

March 6, 2025
Darcy Daubaras
Chief Financial Officer
HIVE Digital Technologies Ltd.
Suite 128, 7900 Callaghan Road
San Antonio, Texas 78229
Re:HIVE Digital Technologies Ltd.
Form 40-F for Fiscal Year Ended March 31, 2024
File No. 001-40398
Dear Darcy Daubaras:
            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 40-F for Fiscal Year Ended March 31, 2024
Notes to the Consolidated Financial Statements
Note 2. Basis of Presentation and Material Accounting Policy Information
(e) Revenue recognition, page 7
Please respond to the following and revise your disclosure in future filings as
necessary to address your revenue recognition under IFRS 15:
•Disclose, if true, that the contracts with mining pool operators are terminable at
any time by either party without penalty.
•If they are, revise your disclosure to clarify that as a result of the termination
rights, the mining pool agreement is continuously renewed for accounting
purposes and the accounting duration of your contracts is less than 24 hours.
•Disclose how payments are generally calculated, including the various
components of the payment (for example, block reward, transaction fees, less pool
operator fee) and the period over which the computations take place (for example,
generally midnight to midnight UTC).
You disclose that the Group recognizes the revenue on a daily basis on the day it •1.

March 6, 2025
Page 2
was received. Disclose whether revenue is recognized on the same day that
control of the contracted service transfers to the mining pool operator. Refer to
IFRS 15.31.
•Revise your disclosure to clarify the timing and method of valuing the noncash
consideration received.
Note 24. Financial Instruments and Risk Management, page 38
2.We note your disclosure that, "the Company's investment holdings that are not traded
in active markets by the Company are considered investments."  We further note that
you account for the majority of your investments using Level 1 inputs, which
indicates quoted prices (unadjusted) in active markets.  Please tell us the following
concerning your investments:
•How you determined that using Level 1 input is appropriate.  Refer to paragraphs
76-90 of IFRS 13.
•If you are not using Level 1 inputs, please revise future filings to disclose the
specific valuation techniques and inputs used to determine fair value and make
sure your disclosures are consistent with the requirements starting in paragraph 91
of IFRS 13.
Note 25. Digital Currency and Risk Management, page 47
3.We note your disclosure of the impact of a 5% variance in price for Bitcoin. Please
tell us how you determined that a 5% impact was appropriate given the price volatility
of Bitcoin in the periods presented.  Please provide more robust sensitivity analysis in
future filings.  Refer to paragraphs 40-42 of IFRS 7.
            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 Jason Niethamer at 202-551-3855
with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets