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BITMINE IMMERSION
TECHNOLOGIES, INC.

2030 Powers
Ferry Road SE, Suite 212

Atlanta, Georgia
30339

October 4, 2024

Mr. David Irving

Michelle Miller

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-3561

 Re: Bitmine Immersion Technologies, Inc.

    Form 10-K Filed December 14, 2023

Form 10-Q
Filed January 12, 2024

    File No. 000-56220

Dear Mr. Irving and Ms. Miller:

Set forth below are the responses of
Bitmine Immersion Technologies, Inc. (the “Company”, “we”, “us” or “our”)
to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter dated July 8, 2024, with respect to the Company’s Form 10-K for the year
ended August 31, 2023 and its Form 10-Q for the quarter ended February 29, 2024 (the “SEC Reports”). The Company notes
that it has recently filed its Form 10-Q for the three months ended May 31, 2024 (the “Current Form 10-Q”), in which
some of the comments have been addressed.

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.

Response: The Company is aware of its obligations
in regard to the Order, and has complied with regard to any Exchange Act reports filed since the Order was issued.

Mr. David Irving and Ms. Michelle Miller

October 4, 2024

Page 2 of 5

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.

Response: To date, the Company has only financed
the purchase of its hosting and mining equipment from a combination of debt financings and equity offerings where the capital raised is
available for use for general corporate purposes, including both equipment purchases and general and administrative expenses. Therefore,
there is no practical way to determine how much of the purchase price of any item of equipment is attributable to a particular debt or
equity offering. Furthermore, to the extent part of an equipment purchase is traceable to an equity offering, there is no possible way
to determine the cost of capital of that financing. Thus, any estimate of the financing costs for any period would be subject to such
a high degree of guesswork and speculation that it risks being misleading to investors. Finally, as mentioned in our prior response to
this same comment, no other industry participants include financing costs in their breakeven analysis, and we believe it is for the same
reasons.

 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.

Response: The Current Form 10-Q includes an additional
footnote that adds the requested information.

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).

Mr. David Irving and Ms. Michelle Miller

October 4, 2024

Page 3  of 5

Response: The Company believes that treating a contract
as a minute-by-minute (or even a second-by-second) contract is not required by the cited accounting literature and would impose unprecedented
accounting and administrative costs on companies to achieve only a slight change in revenues that would be immaterial to investors. While
a parenthetical in the Q&A cited in the Comment raises the possibility of a minute-by-minute contract, we note that the examples that
follow the passage do not treat the subject contracts as minute-by-minute contracts when they could have, and no other examples in the
Q&A treat a contract as a minute by minute contact when the example involves a contract terminable at will by one or both parties.
Contractual relationships that are terminable at will be one or both parties are common. Adoption of such a rule would require that all
companies that follow GAAP implement accounting systems to record the minute of material contract events, such as the execution or termination
of a contract, in order to properly allocate revenues and/or costs between accounting periods before and after the event, which is something
that we do not believe any company currently does. If that level of record keeping is required, it represents a significant change to
normal legal and accounting practices, and therefore should have been more broadly and openly mentioned in the accounting releases than
in a minor parenthetical without any examples demonstrating the practice, or any clarification as to when accounting to the minute is
required, as opposed to conventional accounting on a daily basis. Further, if the Company is held to this standard, then all companies
should be held to this standard for all contracts that are terminable at will by one or both parties.

In addition, the Company could not practically implement
this standard on a minute-by-minute basis because it does not have a reliable way to know how much bitcoin it earns each minute. The amount
of hash calculations that produce bitcoin is not an even amount over the day for the reasons described in response to Comment No. 5, as
the amount varies during the day due to peak usage outages at different geographic areas where miners are hosted, maintenance outages
by either the Company or the hosting firm and permitted outages by the hosting firms or pool operator. The counterparty does not report
how many hash calculations the Company provides each minute of each day. Further, the Company’s own internal estimates of hash calculations
are not reliable because they do not take into account the downtime that the pool operator is permitted on a daily basis. Finally, the
formula for determining the Company’s share of bitcoin earned is a daily calculation, and the counterparty is not equipped to calculate
the Company’s compensation on a minute-by-minute basis.

 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.

Response: The Company disputes that conclusion.
While the Company may have control over scheduled maintenance, all of the other items are outside the Company’s control. The Company
has no control over when a particular miner breaks down mid-day. It also has no control over the time periods in which mining activity
is temporarily shut down during periods of peak usage. Peak usage is partly driven by local weather events that impact usage of air condition
and heating, for example, and the Company has no control over the weather. Finally, where the Company’s miners are hosted by third
parties, the Company has no control over scheduled maintenance by the hosting firm. Even the pool operator only guarantees 98% uptime
of the pool, and the Company has no control over downtime by the pool operator. In short, there is no way that the Company can predict
the amount of hash calculation services at the beginning of any given calendar day due to the foregoing factors.

Mr. David Irving and Ms. Michelle Miller

October 4, 2024

Page 4  of 5

Cryptocurrencies, page F-11

 6. 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.

Response: The Company plans to adopt ASU 2023-08
as of September 1, 2024, the start of its next fiscal year. The adoption of ASU 2023-08 will result in the Company recording bitcoin on
a fair value basis. With regard to past periods, the Company conducted a materiality analysis under SAB 99 to determine if a restatement
of past financial statements would be necessary as a result of assessing for impairment on a daily basis at the lowest reported price
for the day as opposed to only at quarter end, and concluded that a restatement was not necessary. The change would only impact two line
items in operating expenses: realized gain (loss) from the sale of bitcoin and impairment of cryptocurrency. In general, where bitcoin
decreases in value after the date it is earned, and is sold at its lowest reported price, the entire loss would be reflected in “impairment
of cryptocurrency” instead of “realized gain (loss) on sale of cryptocurrency”, but there would no change to operating
income or net income. Where bitcoin is sold for more than its lowest reported price but less than its cost of acquisition, the total loss
recorded by the Company does not change, but an impairment loss is recorded at the lowest price which is offset by a realized gain when
the bitcoin is sold above the lowest price, and again there is no change to operating income or net income. Finally, where bitcoin increases
in value between the date it is earned and the date it is sold, without an interim impairment adjustment, there is no change to the Company’s
net income as the realized gain amount would not change. Note, the Company’s materiality analysis only computed the amount of the
increase in “impairment of cryptocurrency” that would be recorded in each period as a result of assessing for impairment daily
instead of only at quarter end, but did not compute the increase in the “realized gain on sale of cryptocurrency” that would
result, and would largely offset the impairment expense, because the impact on the Company’s financial statements was already immaterial
when taking into account only the increased impairment expense.

Mr. David Irving and Ms. Michelle Miller

October 4, 2024

Page 5   of 5

 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.

Response: In the Current Form 10-Q, the revenue
policy disclosure has been amended to clarify the point raised by the comment.

In connection with responding to the Staff’s
comments, we acknowledge that:

·
the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

·
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with
respect to the filing; and

·
the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

  Sincerely,

  BITMINE IMMERSION TECHNOLOGIES, INC.

  /s/ Jonathan Bates

  Jonathan Bates

  Chief Executive Officer

  Cc:
  Robert J. Mottern, Davis Gillett Mottern and Sims, LLC

MEMORANDUM FOR THE FILES

Date: October 4, 2024

Subject: SAB 99 Analysis to Address Materiality

Background:

Pursuant to a comment letter received by the Company
from the Securities and Exchange Commission (“SEC”) on July 8, 2024, the Company is responding to comment 6. in which the
SEC has asked for the following information:

“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”.

The following memo provides both a quantitative
and qualitative analysis required under SAB 99 to determine whether the recognition of unrealized impairment losses on a daily basis,
instead of only at quarter-end, would result in a material change in the Company’s financial statements. The analysis reflects that
the change would result in additional unrealized impairment losses, but that the additional unrealized impairment losses were immaterial.
Because the additional unrealized impairment losses were found to be immaterial, the Company did not compute the increase in realized
gains that would result from the decreased basis that results from taking daily unrealized impairment losses, and which would offset any
impact of the increased impairment losses, and which would further support the conclusion that the financial statement changes are immaterial.

    Q-1 Ended
    Q-2 Ended
    Q-3 Ended

    11/30/2023
    2/29/2024
    5/31/2024

    Impairment at FIFO using the lowest intraday price
    $ (149 )
    $ (14,526 )
    $ (40,880 )

    Cumulat