SecProbe.io

July 8, 2024
Jonathan Bates
Chief Executive Officer
Bitmine Immersion Technologies, Inc.
2030 Powers Ferry Road SE
Suite 212
Atlanta, Georgia 30339
Re:Bitmine Immersion Technologies, Inc.
Form 10-K for Fiscal Year Ended August 31, 2023
Form 10-Q for Fiscal Quarter Ended February 29, 2024
Response Letter dated April 26, 2024
File No. 000-56220
Dear Jonathan Bates:
            We have reviewed your April 15, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our March 1, 2024 letter.
Form 10-K For the Fiscal Year Ended August 31, 2023
General
1.On May 3, 2024, the Commission entered into an order instituting settled administrative
and cease-and-desist proceedings against BF Borgers CPA PC and its sole audit partner
Benjamin F. Borgers CPA (individually and together BF Borgers). Please refer to the
order on the SEC’s website at https://www.sec.gov/files/litigation/admin/2024/33-
11283.pdf and the related staff statement at
https://www.sec.gov/corpfin/announcement/staffstatement-borgers-05032024. Because
BF Borgers has been denied the privilege of appearing or practicing before the
Commission, issuers that have engaged BF Borgers to audit or review financial
information to be included in any Exchange Act filings to be made on or after the date of
the Order need to engage a new qualified, independent, PCAOB-registered accountant.

July 8, 2024
Page 2
Part I
Item 1. Business, page 1
2.We note your response to prior comment 4 wherein you state that there is no practical way
to determine the financing costs for your miners. In your response to us please explain in
greater detail why you believe you cannot determine the financing costs for your miners.
It appears that such costs could have a material impact on your breakeven analysis.
3.We note your breakeven analysis provided in response to prior comment 4. By a footnote
or parenthetical, please disclose what is included in "Other direct costs of mining per
bitcoin mined" under Owned Facilities in future filings.
Notes to Consolidated Financial Statements
Note 1 - Basis of Presentation and Summary of Significant Policies
Revenues From Digital Currency Mining, page F-8
4.We note your response to prior comment 14. In response 9 in your letter dated January 12,
2024, as well as your accounting policy disclosure, you state that the mining pool contract
can be terminated by either party at any time without penalty. Per question 7 to the FASB
Revenue Recognition Implementation Q&As, such an arrangement would result in a
contract that does not extend beyond the services already provided (i.e. a single hash
calculation).  As such, it appears mining pool services are transferred many times a
day, the contract is renewed continuously, and contract duration is for a less than a 24-
hour period (regardless of when/how payment is processed). Please revise your
accounting and disclosure throughout your policy footnote to be consistent with ASC 606
and the related FASB Q&A in future filings. In that regard, we note that ASC topic 606-
10-32-21 states “an entity shall measure the estimated fair value of the noncash
consideration at contract inception (that is, the date at which the criteria in paragraph 606-
10-25-1 are met).
5.We note your response to prior comment 15. In your response you identify instances of
when miners may be taken off-line  during the day .  It appears that the decision to curtail
mining in response to these events is within the company’s influence. Therefore, since the
only formula input that can change at contract inception with respect to block rewards is
the rate at which you provide hash calculations, which you decide, please revise your
disclosure in future filings to remove disclosure related to the constraint of block rewards.
Cryptocurrencies, page F-11
We note your response to prior comment 16. Per ASC Topic 350-30-35-18 an intangible
asset that is not subject to amortization shall be tested for impairment annually and more
frequently if events or changes in circumstances indicate that it is more likely than not
that the asset is impaired. It appears that the sale of an identical asset, at any period during
a day, for a price less than the Company’s current carrying value, would be an indicator
that it is more likely than not that the asset is impaired. As such, it remains unclear why
you would not conduct an impairment test at that time. We further note that per ASC
Topic 350-30-35-20 subsequent reversal of a previously recognized impairment loss is
prohibited. Please provide a SAB 99 analysis to address materiality in the periods
presented from your current impairment policy to one in which you assess cryptocurrency
impairment based on lowest intraday price.6.

July 8, 2024
Page 3

7.We note your revised digital currency mining revenue policy disclosure on page 11 of
your 10-Q for the three months ending February 28, 2024. In your revised disclosure you
state that you are entitled to compensation equal to the expected reward. However, your
disclosure also implies you receive a share of the rewards paid to the pool operator for
successful efforts. Please revise your disclosure in future filings to reconcile the two
statements and clearly state that as a participant in an FPPS mining pool your
compensation is not contingent on the pool operator successfully placing a block.
            Please contact David Irving at 202-551-3321 or Michelle Miller at 202-551-3368 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jessica Livingston at 202-551-3448 or John Dana Brown at 202-551-3859 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets