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Skadden,
Arps, Slate, Meagher & Flom llp

    One Manhattan West

New York,
NY 10001
    FIRM/AFFILIATE

 OFFICES

    ________
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    BOSTON

    TEL: (212) 735-3000
    CHICAGO

    FAX: (212) 735-2000
    HOUSTON

    www.skadden.com
    LOS ANGELES

    PALO ALTO

    WASHINGTON, D.C.

    WILMINGTON

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    BEIJING

    BRUSSELS

    FRANKFURT

    HONG KONG

    LONDON

    MUNICH

    PARIS

    SÃO PAULO

    SEOUL

    SHANGHAI

    SINGAPORE

    TOKYO

    TORONTO

    September 9, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Crypto Assets

100 F Street, NE

Washington, D.C. 20549

 Attn: Kate Tillan

Rolf Sundwall

 Re: Bitfarms Ltd.

Form 40-F for the Fiscal Year Ended December
31, 2023

Filed March 7, 2024

File No. 001-40370

SEC Staff letter dated July 31, 2024

Dear Ms. Tillan and Mr. Sundwall,

On behalf of Bitfarms Ltd.
(the “Company”), we hereby provide responses to comments received from the staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) by letter dated July 31, 2024 (the “Comment Letter”) with respect to
the above-referenced Form 40-F for the fiscal year ended December 31, 2023 (the “2023 40-F”) filed with the Commission on
March 7, 2024.

Securities and Exchange Commission

September 9, 2024

Page 2

The headings and paragraph
numbers in this letter correspond to those contained in the Comment Letter. To facilitate the Staff’s review, we have reproduced
the text of the Staff’s comments in bold and italics below, followed by responses from the Company. Capitalized terms used but not
defined herein have the meanings given to them in the 2023 40-F. All references to page numbers and captions (other than those in the
Staff’s comments and unless otherwise stated) correspond to the page numbers and captions in the 2023 40-F.

In addition, as noted in further detail below, we are including the
following appendix to the information requested in the Letter to facilitate the Staff’s review and to illustrate how the Company
will disclose its accounting policy information in future filings:

 ● Appendix A – Proposed draft excerpts of
the Company’s applicable material accounting policy information to be included in future filings with the Commission where a detailed
description of the Company’s accounting policies is included.

Form 40-F for the Fiscal Year Ended December
31, 2023

Recovery of Erroneously Awarded Compensation,
page 7

 1. It appears that you have not provided your disclosure
about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In
future filings where you conduct a recovery analysis, please also include the interactive data.

The Company
respectfully acknowledges the Staff’s comment and in future filings will provide disclosure about its recovery analysis in an
interactive data file.

Consolidated Statements of Cash Flows, page
F-7

 2. We acknowledge your responses to comment 1 from our
letter dated June 26, 2023 and comment 1 from our letter dated September 18, 2023. Please revise to classify the proceeds from sales
of your digital assets, which are classified as intangible assets, within investing activities consistent with the requirements of IAS
7.16(b).

The Company respectfully
acknowledges the Staff’s comments and believes that the classification of proceeds from sales of digital assets in the statements
of cash flows is not absolute and there are instances when it is more appropriate to classify the proceeds as operating or investing activities.
For example, in fiscal 2022, which was the last time the Company purchased Bitcoin, the Company reported the cash flows received from
selling the purchased Bitcoin within investing activities since the generation of the Bitcoin did not arise from the Company’s operating
activities but rather from actions conducted expressly as an investment activity.

Securities and Exchange Commission

September 9, 2024

Page 3

The Company believes the
proceeds from sales of Bitcoin mined is more appropriately reflected as an operating cash flow for the Company’s business operations
which is consistent with IAS 7.11 that states “An entity presents its cash flows from operating, investing and financing activities
in a manner which is most appropriate to its business”. The Company normally and regularly sells its Bitcoin for cash to pay operating
expenses and believes the ultimate cash inflow received from its primary revenue-generating activity should be presented as an operating
activity in the Company’s statements of cash flows, which is consistent with IAS 7.14 that states “Cash flows from operating
activities are primarily derived from the principal revenue-producing activities of the entity”.

Presenting
proceeds from sales of digital assets within investing activities would preclude investors from assessing the impact of the Company’s
operating activities on the financial position of the Company and its cash and cash equivalents, and could result in confusion
given that the direct costs for generating revenue are classified
within operating activities. The Company believes such a presentation would be inconsistent with IAS 7.11.

In addition, IAS 7.13 states
“The amount of cash flows arising from operating activities is a key indicator of the extent to which the operations of the
entity have generated sufficient cash flows to repay loans, maintain the operating capability of the entity, pay dividends and
make new investments without recourse to external sources of financing.” The Company sells its Bitcoin to cover costs and expenses
during its normal operating cycle. The Bitcoin are sold when needed and to avoid external sources of financing and, accordingly, the proceeds
from the mined Bitcoin sold should be classified as operating activities in the Company’s statements of cash flows. The Company
believes classification between operating and investing activities is principles-based and requires judgement. The Company classifies
the cash flows received from Bitcoin held for long-term purposes or bought outside of Mining as investing activities.

IAS 7.15 states, “An
entity may hold securities and loans, for dealing or trading purposes, in which case they are similar to inventory acquired specifically
for resale. Therefore, cash flows arising from the purchase and sale of dealing or trading securities are classified as operating activities,”
which demonstrates that the standard allows for flexibility when presenting cash flows in order to reflect the substance of the transactions.
The Company’s turnover of Bitcoin calculation as described in the Company’s response letter dated July 27, 2023, has been
between one and three months from fiscal year 2022 to year-to-date 2024 which demonstrates that the Company normally and regularly sells
its Bitcoin.

In light of the foregoing,
the Company respectfully submits to the Staff that it would be appropriate for the Company to continue to present and disclose the proceeds
from sales of digital assets as operating activities, consistent with its historical practices.

Note 3. Basis of Presentation and Material
Accounting Policy Information

Revenue recognition, page F-12

 3. We acknowledge your response to prior comment 2. Please
respond to the following and revise your disclosure in future filings to specifically address the following concerning your mining revenue
recognition under IFRS 15:

For ease of reference, the
Company has labeled its responses (a through d) below to correspond to the bullets set forth in the Staff’s comment 3.

 Securities and Exchange Commission

September 9, 2024

Page 4

 a) You disclose you entered into arrangements with a mining
pool and have undertaken the performance obligation of providing computing power used for hashing calculations to the mining pool in
exchange for noncash consideration in the form of cryptocurrency, which is variable consideration.

 i. Clarify in your disclosure, if true, that the contracts are with a mining pool operator, the mining
pool operator is your customer, the services you provide to your customer are an output of your ordinary activities, you have a single
performance obligation, and the form of noncash consideration is bitcoin.

The Company
respectfully acknowledges the Staff’s comments and will further clarify the requested disclosure in its financial statements
and all other future filings with the Commission where a detailed description of its accounting policies is included. The Company is
currently in the process of drafting its proposed disclosures (refer to Appendix A hereto) which have not yet been finalized at the
date of this response letter.

 ii. You disclose your performance obligation is to provide computing power used for hashing calculations.
In your response, you told us the mining pool operator dictates how the computing power will be used. Clarify for us the nature of the
services you provide and tell us whether you perform hash calculations for the pool operator. In this regard, we understand that you run
software from the pool operator that constructs block header candidates and performs hash computations on behalf of the pool operator.

The Company respectfully
acknowledges the Staff’s comments and submits to the Staff that the Company has entered into arrangements with a mining pool operator
(which is the Company’s customer) and has undertaken to provide a service to perform hash calculations for the mining pool operator,
which is an output of the Company’s ordinary business activities, in exchange for noncash consideration in the form of Bitcoin.
The Company will further clarify the disclosure in its financial statements and all other future filings with the Commission where a detailed
description of its accounting policies is included. The Company is currently in the process of drafting its proposed disclosures (refer
to Appendix A hereto) which have not yet been finalized at the date of this response letter.

 iii. If you do perform hash calculations for the pool operator, tell us whether a more accurate description
of your promise and single performance obligation is a service to perform hash calculations for the pool operator, and if so, make corresponding
revision to your accounting policy and related disclosures throughout your filing.

The Company respectfully
acknowledges the Staff’s comments and submits to the Staff that the Company has entered into arrangements with a mining pool operator
(which is the Company’s customer) and has undertaken to provide a service to perform hash calculations for the mining pool operator,
which is an output of the Company’s ordinary business activities, in exchange for noncash consideration in the form of Bitcoin.
The Company will further clarify the disclosure in its financial statements and all other future filings with the Commission where a detailed
description of its accounting policies is included. The Company is currently in the process of drafting its proposed disclosures (refer
to Appendix A hereto) which have not yet been finalized at the date of this response letter.

Securities and Exchange Commission

September 9, 2024

Page 5

 b) You disclose the duration of the contract is less than
24 hours and the contract is continuously renewed throughout the day. Tell us your consideration of disclosing that your enforceable
right to compensation begins when and continues as long as you provide services, and you decide when to provide services under the contracts.

The arrangements with the
mining pool operator specify that the FPPS payout methodology is applied in the calculation of revenues earned and the Company is compensated
based on its pay-per-share earnings. The agreements with the mining pool operator state that the Company’s access to and usage of
the mining pool are not contingent on delivering any minimum amount of hashrate and the Company is not bound to continue using the mining
pool, thus allowing the Company to decide when to provide services to the mining pool operator. In light of the foregoing, the Company
respectfully submits to the Staff that no additional changes to the relevant disclosure are required.

 c) You disclose you recognize revenues upon delivery of
the service over a 24-hour period, which generally coincides with the receipt of crypto assets in exchange for the provision of computational
power used for hashing calculations and the contract inception date.

 i. Tell us whether transfer of control of your services is at the same time as upon delivery of the
service over a 24-hour period. If so, clarify the disclosure to refer to when control transfers. Refer to IFRS 15.31.

The Company respectfully
acknowledges the Staff’s comments and submits to the Staff that revenues from providing a service to perform hash calculations for
the mining pool operator are recognized upon delivery of the service, which is when the mining pool operator obtains control of the hash
calculations, over a 24-hour period. The Company will further clarify the disclosure in its financial statements and all other future
filings with the Commission where a detailed description of its accounting policies is included. The Company is currently in the process
of drafting its proposed disclosures (refer to Appendix A hereto) which have not yet been finalized at the date of this response letter.

 ii. Reconcile the disclosure that the timing of the receipt of the crypto assets coincides with the
delivery of the service with your response that you receive the noncash consideration a few hours after the end of day you provide that
service and revise your disclose accordingly.

The Company respectfully
acknowledges the Staff’s comments and will further clarify the disclosure in its financial statements and all other future filings
with the Commission where a detailed description of its accounting policies is included. The revised disclosure will not refer to the
receipt of crypto assets as coinciding with the delivery of the service. The Company is currently in the process of drafting its proposed
disclosures (refer to Appendix A hereto) which have not yet been finalized at the date of this response letter.

 Securities and Exchange Commission

September 9, 2024

Page 6

 d) Explain further your response that you (a) recognize
revenue only after receiving confirmation from the mining pool when analyzing IFRS 15.46 and (b) recognize revenue throughout the 24-hour
period and update the estimated transaction price each day, after the 24-hour period is completed since these two statements appear to
be contradictory. We note that the requirements of IFRS 15.31 indicate that recognition occurs upon the transfer of control of the service,
not upon receipt of confirmation.

 i. As applicable, revise your accounting policy to comply with IFRS 15, noting that in the last paragraph
in Note 3.b.i. on page F-13 you state that revenues are recognized upon delivery of the service over a 24-hour period yet tie that recognition
to receipt of consideration. Tell us if applying the corrected policy to historical periods results in a material change to the historical
financial statements presented.

With respect to the Staff’s
question regarding the analysis of IFRS 15.46 from the Company’s previous response letter dated October 5, 2023, the Company wishes
to modify and supplement its prior response by clarifying and confirming that the Company has historically recorded the revenue after
the confirmation is received for practical purposes. The first paragraph of the Company’s analysis of 15.46 explained that the Company
recognizes revenue over time, which is consistent with the Company’s 2023 40-F accounting policy disclosure and the requirements
of IFRS 15.31. There are no material changes to historical financial statements required as the policy has been consiste