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October 5, 2023

Securities and Exchange Commission

Division of Corporation Finance

Office of Crypto Assets

100 F Street, NE

Washington, D.C. 20549

Attn: Kate Tillan and Rolf Sundwall

 Re: Bitfarms Ltd.

Form 40-F for the Fiscal Year Ended December 31, 2022

Filed March 21, 2023

File No. 001-40370

Dear Ms. Tillan and Mr. Sundwall,

On behalf of Bitfarms Ltd. (the “Company”),
I am responding to the comments contained in the letter dated September 18, 2023 (the “Letter”) from the staff of the Securities
and Exchange Commission (the “Commission” and, the staff of the Commission, the “Staff”) to Jeffrey Lucas, Chief
Financial Officer of the Company, relating to the Company’s Form 40-F for the fiscal year ended December 31, 2022 (the “2022
40-F”). The responses contained herein are keyed to the numbers of the comments in the Letter, which appear in italics below for
convenience of reference. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the 2022 40-F.
As an initial matter, the Company notes that the only digital assets mined, purchased and sold by the Company during the years ended December
31, 2021 and 2022 as well as year-to-date in 2023 were Bitcoin.

In addition, as noted in further detail below,
the following appendices are included with this response to the information requested in the Letter:

 ● Appendix A – Mining pool service agreement (which has
been redacted with respect to confidential pricing information)

 1. We acknowledge your response to comment 1. IAS 7.16 states that only
expenditures that result in a recognized asset in the statement of financial position are eligible for classification as investing activities
and examples of cash flows arising from investing activities include cash receipts from sales of property, plant and equipment, intangibles
and other long-term assets. We note that your digital assets are classified as an intangible asset, even though you classify this asset
as a current asset. Your discussion of IAS 7.16(b) seems to dismiss its applicability simply because your digital assets are classified
as current assets. Since we note that IAS 7.16(b) specifically refers to sales of intangible assets, please tell us further about your
consideration of this guidance.

Response: To supplement our previous
response regarding the presentation of the disposition of digital assets mined being classified as an operating activity, we note that
IAS 7.16 states that “the separate disclosure of cash flows arising from investing activities is important because the cash flows
represent the extent to which expenditures have been made for resources intended to generate future income and cash flows. Only expenditures
that result in a recognized asset in the statement of financial position are eligible for classification as investing activities.”
In our response, we did not mean to suggest that an asset classified as “current” would be determinative in the classification
of the cash flow between operating and investing. We acknowledge that an acquisition of a current asset could qualify as investing cash
flow, and not an operating cash flow.

    1

We considered the following when evaluating the
classification of our cash flows associated with earning Bitcoin:

We believe an important consideration is IAS 7.11,
which states, “an entity presents its cash flows from operating, investing and financing activities in a manner which is most appropriate
to its business. Classification by activity provides information that allows users to assess the impact of those activities on the financial
position of the entity and the amount of its cash and cash equivalents. This information may also be used to evaluate the relationships
among those activities.”

The examples listed in IAS 7.16 are examples for
cash flow presentation and do not represent a rigid set of rules. So, while we recognize that our revenue-generating operating activities
(the generation of computing power) are settled with Bitcoin, which is an intangible asset, we usually sell the Bitcoin for cash. We believe
the ultimate cash inflow received from our primary revenue-generating activity is more appropriately reflected as an operating cash flow,
as these cash flows are reflective of the cash effects of events that enter into the determination of net income. The alternative to presenting
the settlement of our revenue contracts as being a “non-cash revenue component” within operating cash flows, and the cash
inflow from disposal of Bitcoin as an investing cash flow, would not allow users to assess the impact of our operating activities on the
financial position of the Company and its cash and cash equivalents. It would reflect a much higher cash flow generation from investing
cash inflows (without the corresponding cost outflow) and all of the cash outflows within operating activities. Cash flows from operating
activities are generally the cash effects of events that enter into the determination of net income.

The Company considers the specific circumstances
and a transaction’s substance when determining the presentation of items in the statements of cash flows and ensures that there
is consistency of treatment between the statements of cash flows and the other primary statements in order to provide the readers of the
financial statements with a better understanding of how the Company generates and expends cash. The Company expends cash (our operating
cash outflow) by purchasing electricity to power miners to produce computational power in exchange for Bitcoin, which is sold for cash.
The act of generating the asset is operational and, therefore, so should the immediate sale of Bitcoins “earned” in the revenue-generating
activity. We believe this type of ‘Bitcoin acquisition’ is very different from the Company purchasing Bitcoin from a third
party and subsequently selling it.

We did consider IAS 7.16(a) and (b). Specifically,
we noted that IAS 7.16(a) refers to “cash payments to acquire property, plant and equipment, intangibles and other long-term
assets. These payments include those relating to capitalized development costs and self-constructed property, plant and equipment.”
The Company differentiates between the cash proceeds from the sale of Bitcoin that it has purchased in an investing cash outflow (i.e.,
the cash inflow relating to the cash payment originally made to acquire an intangible asset) and cash proceeds the company receives from
the sale of Bitcoin it has “earned” through its mining activities (i.e., the cash received for the Bitcoin sold within the
Company’s normal operating cycle that was originally earned in exchange for its services, which is delivering computational power
as part of the core of the Company’s operating activities). It is important to note that the Company presents its cash expenditures
(i.e., energy expense included in net income) as an operating cash flow, and therefore reports proceeds from the sale of Bitcoin mined
as operating activities as well.

The Company presents its purchases of Bitcoin
as an investing activity (direct cash outflow to purchase an intangible asset) and any corresponding sale of purchased Bitcoin as a cash
inflow from investing activities. This presentation represents the nature of the cash flows.

    2

 2. We acknowledge your response to comment 2. Please respond to the following:

 ● We note from Appendix A that the terms of service may change. Confirm that the version you sent to
us covers the financial statement periods included in your Form 40-F and provide us with any new versions that were issued subsequent
to the financial statement periods presented.

 ● Your response told us that you only have one mining pool customer, but your disclosure refers to contracts
with mining pools. Tell us why.

 ● With respect to step one of IFRS 15, tell us how you considered when contract inception occurs and
the duration of the contract. Tell us how you considered the termination provisions of the contract including sections 3(d) and 8. Refer
to IFRS 15.9 - 15.17.

 ● With respect to step 2 of IFRS 15, we note that Appendix B to the contract refers to the payment of
a flat amount of BTC for each share submitted to the pool. Respond to the following:

 ○ Tell us what a share represents and whether the share is your performance obligation.

 ○ Substantiate how the provision of computing power to the mining pool is your sole performance obligation.

 ○ Tell us whether it is possible to provide computing power that does not result in valid shares.

 ○ Tell us how/when you report your work performed to the mining pool operator.

 ● With respect to step three of IFRS 15, you told us that your computing power (hashrate) is transferred
to the mining pool over a 24-hour period. You disclose that revenue from contracts with customers is recognized when control over the
goods or services is transferred to the customer. Tell us at what point control over the goods or services is transferred to the customer
and whether you satisfy your performance obligation over time or at a point in time and why. Refer to IFRS 15.31 - 15.46.

 ● With respect to step four of IFRS 15, tell us whether the consideration includes a variable amount
and, if so, how you constrain estimates of variable consideration. Refer to IFRS 15.47 - 15.59.

 ● With respect to your non-cash consideration, you told us that you measure
the Bitcoin earned and received from mining activities based on the price quoted on the day the Bitcoin are received as that measurement
time is a few hours after the company completes its performance obligation of providing its hashrate for 24 hours. We note from BC253
of IFRS 15 that the boards observed that once recognized, any asset arising from the non-cash consideration would be measured and accounted
for in accordance with other relevant requirements. Tell us how you considered the guidance in IFRS 15 since it appears that the timing
of your measurement of the fair value of the non-cash consideration is in a period following when revenue is recognized. Refer to IFRS
15.66 - 15.69.

 ● With reference to Section 7 of the agreement, tell us how you account for pool fees paid to the mining
pool. Refer to IFRS 15.70 - 15.72

Response: The version of Appendix A included
in the Company’s July 27, 2023 response letter covers the financial statement periods included in the Company’s 40-F. The
Company has included as Appendix A hereto the current version of the mining pool service agreement (the “service agreement”)
dated as of August 28, 2023, which has been redacted with respect to confidential pricing information.

    3

The Company disclosed that it had contracts with
mining pools, in the plural, only because it was a member of another mining pool at the beginning of fiscal 2021 before switching to Foundry
USA Pool and has not changed mining pools since then. The Company will update its disclosure in its future annual reports and any other
future filings with the Commission where a detailed description of its accounting principles is included. The change will refer to a contract
as being with “a mining pool.”

With respect to step 1 of IFRS 15, the Company
considered the daily payout as the key element for the contract inception and duration of the contract. This is consistent with section
11 of the service agreement. Sections 3(d) and 8 of the previous service agreement implied that the service agreement was an indefinite
contract and could be terminated by the mining pool at any time. The new service agreement is explicit that the contract is a 24-hour
period contract that automatically renews each day. The Company or the mining pool can terminate the agreement by notifying the other
party with at least one day prior written notice.

In connection with identifying the contract with
a customer, we have considered IFRS 15.9 to 15.17. Our specific responses to factors for consideration are in red.

 9 An entity shall account for a contract with a customer that is within the scope of this Standard only when all of the following criteria are met:

(a) the parties to the contract have
approved the contract (in writing, orally or in accordance with other customary business practices) and are committed to perform their
respective obligations; YES – the Company successfully completed the client onboarding process required
by the mining pool in order to conduct business with the mining pool. Both parties (Foundry and the Company) approve the contract, and
are committed to perform their respective obligations.

(b) the entity can identify
each party’s rights regarding the goods or services to be transferred; YES – the Company’s
obligation is to irrevocably transfer computational power to the mining pool without any right of rescission.

(c) the entity can identify the payment terms
for the goods or services to be transferred; YES – under the written terms of the contract, revenues
earned within a 24-hour period represent fees earned for the transferred computational power. The fees are calculated based on the estimated
block reward plus the estimated transaction fees.

(d) the contract
has commercial substance (ie the risk, timing or amount of the entity’s future cash flows is expected to change as a result of the contract);
and YES – the Company’s miners consume electricity and generate computational power which, as
the performance obligation, is transferred to the customer and settled in Bitcoin. The cash arising from the settlement of the non-cash
consideration results in revenues under this commercial agreement, and an operating gross margin.

(e) It is probable that the entity will collect
the consideration to which it will be entitled in exchange for the goods or services that will be transferred to the customer. In evaluating
whether collectability of an amount of consideration is probable, an entity shall consider only the customer’s ability and
intention to pay that amount of consideration when it is due. The amount of consideration to which the entity will be entitled may be
less than the price stated in the contract if the consideration is variable because the entity may offer the customer a price concession
(see paragraph 52). YES – the mining pool transfers payment daily, in the form of Bitcoin consideration,
to the Company as part of the full-pay-per-share (“FPPS”) payout scheme of the mining pool contract.

    4

10 A contract is an agreement between
two or more parties that creates enforceable rights and obligations. Enforceability of the rights and obligations in a contract is a
matter of law. Contracts can be written, oral or implied by an entity’s customary business practices. The practices and processes
for establishing contracts with customers vary across legal jurisdictions, industries and entities. In addition, they may vary within
an entity (for example, they may depend on the class of customer or the nature of the promised goods or services). An entity shall consider
those practices and processes in determining whether and when an agreement with a customer creates enforceable rights and obligations.
YES – the mining pool’s terms of service are contractual with enforceable rights and actions.

11  Some contracts with customers
may have no fixed duration and can be terminated or modified by either party at any time. Other contracts may automatically renew on a
periodic basis that is specified in the contract. An entity shall apply this Standard to the duration of the contract (ie the contractual
period) in which the parties to the contract have present enforceable rights and obligations. The previous
service agreement did not have a fixed duration. The new service agreement specifies that the contract automatically renews on a daily
basis, which is consistent with the daily earnings and payouts methodology.

12  For the purpose of applying
this Standard, a contract does not exist if each p