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 April 24, 2025

Jonathan Bates
Chief Executive Officer
Bitmine Immersion Technologies, Inc.
10845 Griffith Peak Drive, #2
Las Vegas, NV 89135

 Re: Bitmine Immersion Technologies, Inc.
 Amendment No. 2 to
 Registration Statement on Form S-1
 Filed April 9, 2025
 File No. 333-284361
Dear Jonathan Bates:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No. 2 to Form S-1
General

1. We note that your registration statement includes a number of blanks or
omitted
 information, including, without limitation:
 the exchange on which your common stock will be listed;
 the number of shares that will be available for sale into the market
if the
 restrictions under the lock-up agreements with your directors,
executive officers
 and holders of 5% or more of your common stock are waived (page 48);
and
 certain information related to the annual management fee and
performance
 allocation IDI is entitled to pursuant to the line of credit (pages
73 and 102).
 Please include this information in your next amendment, or tell us when
you intend to
 do so.
 April 24, 2025
Page 2

Cover Page

2. We note in the first paragraph that you are offering 1,704,546 shares of
your common
 stock. Please revise here and throughout your Prospectus to also
disclose the total
 number of shares you are offering assuming the underwriters exercise the
over-
 allotment option in full.
The Offering
Shares of Common Stock Outstanding before the Offering, page 11

3. Please revise to disclose the total number of shares of your common
stock outstanding
 giving effect to the anticipated conversion of your Series A and B
preferred stock
 and indebtedness due to an affiliate. Please make similar revisions to
your disclosure
 in the second paragraph on page 104 under Principle Stockholders and
elsewhere in
 your Prospectus, as appropriate.
Risk Factors
Risks Related to Ownership of Our Common Stock
Exercise or conversion of warrants and other convertible securities, page 43

4. Please revise this risk factor to disclose, on a post-split basis, the
number of shares of
 common stock the shares of Series A Convertible Preferred Stock are
convertible into,
 the number of shares of common stock the shares of Series B Convertible
Preferred
 Stock are convertible into, and the total of the two.
 Please contact Lulu Cheng at 202-551-3811 or David Gessert at
202-551-2326 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Lynne Bolduc, Esq.
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