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       November 12, 2024

      CONFIDENTIAL SUBMISSION VIA EDGAR

      Sonia Bednarowski

      U.S. Securities and Exchange Commission

      Division of Corporation Finance

      100 F. Street, N.E.

      Washington, D.C. 20549

            Re:

              Exodus Movement, Inc.

                Amendment No. 4 to Registration Statement on Form 10-12G

              Filed October 10, 2024

              File No. 000-56643

      Dear Ms. Bednarowski:

      Set forth below are the responses of Exodus Movement, Inc. (“Exodus” or the “Company”), in response to the comments of the staff of the Securities and Exchange Commission (the “SEC”) Division of Corporation Finance
        (the “Staff”) contained in your letter, dated October 31, 2024 (the “Comment Letter”), regarding the above-referenced Amendment No. 4 to the Registration Statement on Form 10-12G, (as amended by Amendment No. 4, the “Registration Statement”). The
        Staff’s comments are set forth below, followed by the Company’s response. For ease of reference, the heading and numbered paragraphs below correspond to the heading and numbered comments in the Comment Letter and, in certain instances, if the
        Staff’s comment contained multiple parts, the Staff’s comment was separated into subparts to more effectively respond to each of the Staff’s comments. The Company’s responses are set forth beneath the Staff comments, which are set out in bold type.
        We are concurrently submitting via EDGAR this letter and Amendment No. 5 (“Amendment No. 5”) to the Registration Statement.

      Amendment No. 4 to Registration Statement on Form 10-12G

      Business

      Our Products and Services, page 4

                1.

                We note news articles about your partnerships with Blockchain.com and Ledger Live. Please revise to add disclosure regarding the XO Swap and Passkey Wallet & SDK products offered on
                  your platform and, to the extent your agreements with Blockchain.com and Ledger Live are material, please revise to disclose the material terms of these agreements. Please refer to Item 601(b)(10) of Regulation S-K.

        1

      The Company acknowledges the Staff’s comment and has revised Amendment No. 5 accordingly. Please refer to pages 5 and 8.

      The Company respectfully advises the Staff that the Company does not believe that the agreements with Blockchain.com or Ledger Live are material or that its business is substantially dependent on
        either agreement. The agreements with Blockchain.com and Ledger Live are of the type that ordinarily accompanies the type of business conducted by the Company, and the Company is not substantially dependent upon either agreement.  The financial
        terms of each agreement are immaterial in amount and significance to the Company’s financial statements. In addition, neither agreement contains any exclusive licenses or contains any milestone or royalty obligations.

      Pricing Information Offered Directly on the Exodus Platform, page 5

                2.

                We note your response to prior comment 1. Please revise your disclosure on page 5 to describe what qualifies as a “material” variance.

      The Company acknowledges the Staff’s comment and has revised Amendment No. 5 to describe what qualifies as a “material” variance. Please refer to page 5.

      Also revise to disclose, if true, that, if a material variance occurs between the primary and secondary providers without a material variance between the primary
          provider and the tertiary provider, the platform continues to display the primary provider’s updated pricing information.

        The Exodus Platform does not check for the existence of a material variance (15%) between the primary provider and the tertiary provider. This is because the Exodus Platform
          already checks (a) the primary provider’s pricing information against the secondary provider’s pricing information and (b) the secondary provider’s pricing information against the tertiary provider’s pricing information. Thus, in a situation
          where the primary provider’s pricing information differs from the secondary provider’s pricing information, the Company believes that the lack of a material variance between the secondary provider and the tertiary provider is sufficient support
          for the Exodus Platform to show the secondary provider’s price without conducting an additional check between the primary provider and the tertiary provider.

          However, as disclosed in the Registration Statement, the Exodus Platform does check for widespread variances, considered to exist if there is a 2% variance in price across
            the primary and secondary providers and the additional verification source (e.g., due to a widespread outage across multiple service providers). In this situation, the Exodus Platform will continue to show the primary provider’s most recently
            available price before the 2% widespread variance occurred and until such 2% widespread variance no longer exists.

      Services Offered and Performed by Our API Providers, page 5

                3.

                We note your response to prior comment 2. Please disclose the custody arrangements for users’ assets held in lightning wallets provided by Wallet of Satoshi and disclose the risks to
                  users in the event that Wallet of Satoshi experiences insolvency or bankruptcy.

      The Company acknowledges the Staff’s comment and has revised Amendment No. 5 accordingly. Please refer to pages 11, 21 and 32.

      Human Capital Management

      Cryptocurrency Payroll Process, page 14

                4.

                We note your response to prior comment 5. Please revise your disclosure on page 14 to describe how CryptoCompare calculates the bitcoin spot rate.

        2

      The Company respectfully advises the Staff that, given the technical nature of the bitcoin spot rate calculation and in light of the Company’s lack of involvement in such calculation, the Company
        is not in a position to provide disclosure that describes with sufficient certainty the technical processes and mechanics that underpin CryptoCompare’s calculation of its bitcoin spot rate.

      As disclosed in the Registration Statement, the Company contracts with Gilded Inc. (“Gilded”) to help administer the Company’s bulk cryptocurrency payments system; in turn, Gilded contracts with
        CryptoCompare. This means the Company is not in direct privity of contract with CryptoCompare for this payroll function and therefore does not have contractual rights to access and is not otherwise privy to information regarding CryptoCompare’s
        bitcoin spot rate mechanics.  However, in an effort to address any underlying concerns of the Staff with respect to CryptoCompare’s calculations and how this may impact the Company’s payroll function, the Company respectfully notes that the Company
        discloses to its employees and non-U.S. independent contractors that CryptoCompare is Gilded’s source for the bitcoin spot rate, and employees and non-U.S. independent contractors can compare CryptoCompare’s pricing data to other global pricing
        providers if they so choose. To date, the Company has not received any complaints from employees or non-U.S. independent contractors regarding CryptoCompare’s bitcoin spot rate calculation.

      KYC and KYB Programs

      KYB Program For API Providers and Vendors, page 18

                5.

                We note your response to prior comment 7. Please identify the third party that performs the KYB analyses of your API Providers and vendors as well as the material terms of the agreement
                  with the third party.

      The Company engages multiple third parties to assist with its Know your Business (KYB) analyses of API Providers and vendors. Specifically, the Company utilizes and relies on tools from
        Chainalysis, a blockchain analysis firm, Veriff, an identity verification platform, and ComplyAdvantage, an entity that performs sanctions and adverse media screenings. The Company has revised Amendment No. 5 to identify these third-party providers
        and to disclose that such agreements are standard commercial agreements entered into by the Company in the normal course. Please refer to page 19.

      In response to the Staff’s request to identify the material terms of these agreements, the Company notes that these agreements provide for the provision of services for an agreed-upon term and may
        renew automatically for a one-year period, or a period equal to the expiring service period, unless either party provides notice of its intent to not renew the agreement. In addition, the agreements may be terminated by either party for a material
        breach which remains uncured following thirty days’ notice, or where continued performance of the agreement would violate applicable law or regulatory requirements, or in the event of the Company’s insolvency or inability to pay its debts.

        3

       In addition, please describe your internal KYB policy, including the various procedures for documenting, reporting and responding to potential violations of applicable
        sanctions rules, along with the procedures for assessing business relationships with API Providers or vendors that have been the subject of sanction violations.

      The Company’s KYB policy outlines various procedures for documenting, reporting and responding to potential violations of applicable sanctions rules. For example, it is Company policy that Exodus’
        full-time equivalents identify potential “red flags” that may violate the Company’s sanctions policy. These red flags, along with other suspicious activities, must be reported to Exodus’ legal and compliance teams. Once reported, the Company will
        conduct an internal investigation of potential violations of sanctions rules, including by gathering information from internal and third-party sources, analyzing facts surrounding the potential violation, assessing risk to the Company, and taking
        appropriate next steps with regards to such party, including, where appropriate, terminating the business relationship and/or reporting to the Office of Foreign Assets Control, or another relevant regulatory body.

      Our Chief Compliance Officer, who is the dedicated sanctions compliance officer under the Company’s policy, must provide regular reports to the Audit Committee of the Board of Directors confirming
        compliance with sanctions obligations, including highlighting any issues that arise and noting actions taken in response. Copies of all submissions to regulatory authorities and related documentation must be maintained indefinitely or as required
        by the relevant regulatory body.

      Market Price of and Dividends on the Registrant’s Common Equity and Related Stockholder Matters

      Market Information, page 57

                6.

                Your revised disclosure on pages 57 and 58 that Common Stock Tokens are analogous to paper stock certificates conflicts with your disclosure on page 58 that the Class A common stock is a
                  security whose ownership is recorded solely on the books of our transfer agent and the Common Stock Tokens give no ownership interest in the Class A common stock. Please revise to remove the analogy to paper stock certificates or advise.

      The Company acknowledges the Staff’s comment and has removed the analogy to paper stock certificates.

        4

      Digital Format Exodus Common Stock
      The Role of Securitize, page 58

                7.

                We note your response to prior comment 10. On pages 58 and 59, you state that “[e]ach share of Class A common stock has a corresponding Common Stock Token ...” and that “[i]f a record
                  holder of shares of Class A common stock chooses not to self-custody the corresponding Common Stock Tokens, then such holder’s Common Stock Tokens will be held in her name by Securitize.” Please disclose how Securitize transfers the
                  Common Stock Tokens it holds for the Class A stockholders when a Class A stockholder sells shares of Class A common stock.

      The Company acknowledges the Staff’s comment and has revised Amendment No. 5 accordingly. Please refer to pages 60-62.

      In addition, we note your revised disclosure that “[i]n the event of discrepancy, Securitize will investigate such discrepancy and take actions to resolve it, including, but
        not limited to, the reversal of any transactions as the facts and circumstances may warrant.” Please disclose how Securitize can reverse a transaction on the Algorand blockchain.

      The Company respectfully submits that Securitize is registered as a transfer agent under Section 17A(c) of the Securities Exchange Act of 1934 (the “Exchange Act”) and that as a registered
        transfer agent, Securitize must comply with Section 17A’s various reporting, recordkeeping, and other requirements in the rules promulgated thereunder, including Rule 17Ad-10, which serves as a basis for reversing transactions to rectify
        administrative or clerical errors, and Rule 17Ad-11, which requires transfer agents to monitor for record-keeping discrepancies and allows for corrective actions when material discrepancies are found. While the Company is not in a position to opine
        on logistical matters regarding how Securitize complies with its legal obligations, including those under Section 17A, to the Company’s knowledge, Securitize has sufficient controls with respect to the Common Stock Tokens to perform its role as an
        SEC registered Transfer Agent.

      With respect to the Algorand blockchain specifically, the Algorand standard assets allow Securitize to represent any asset on the Algorand blockchain. These standard assets are built into the
        Layer-1 architecture of the Algorand blockchain but are structured in a way that allows Securitize to represent and manage assets on the blockchain platform. In other words, the Algorand standard assets provide a management framework that allows
        Securitize to perform its role as an SEC-registered transfer agent with respect to the Common Stock Tokens. If Securitize was not able to use the Algorand Blockchain in a manner that allowed it to fulfill its legal obligations as an SEC-registered
        transfer agent, we understand that Securitize would  utilize a different blockchain for the Common Stock Tokens that allowed it to comply with its legal obligations as an SEC-registered transfer agent.

        5

      We also note your disclosure on page 59 that, “[w]hile Securitize’s Digital Securities Protocol ... itself is not used on the Algorand blockchain because the Algorand
        blockchain does not support it, Securitize utilizes the Algorand standard assets and internal procedures to govern the Common Stock Tokens that exist on the Algorand blockchain ....” Please add a risk factor that addresses the potential impact to
        Securitize’s ability to utilize the DS Protocol Equivalent to govern the Common Stock Tokens due to modifications of the Algorand blockchain.

      The Company respectfully notes that it is not aware of any material risks that make an investment in Exodus speculative or risky relating to potential modifications of the Algorand blockchain and
        any corresponding impact such modifications may have on Securitize’s governance of the Common Stock Tokens.

      Securitize is an SEC-registered transfer agent under Section 17A(c) of the Exchange Act and subject to the legal requirements applicable thereto. The Company acknowledges that the Common Stock
        Tokens are novel; however, as the Registration Statement clearly discloses, these Common Stock Tokens