SEC Comment Letter 0000000000-24-006122 to Stronghold Digital Mining, Inc. (SDIG) (CIK 0001856028)
Stronghold Digital Mining, Inc. (SDIG) (CIK 0001856028)
Date: May 28, 2024 · CIK: 0001856028 · Accession: 0000000000-24-006122
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File numbers found in text: 001-40931
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United States securities and exchange commission logo
May 28, 2024
Matthew J. Smith
Chief Financial Officer
Stronghold Digital Mining, Inc.
595 Madison Avenue, 28th Floor
New York, NY 10022
Re:Stronghold Digital Mining, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 8-K, Furnished April 25, 2024
File No. 001-40931
Dear Matthew J. Smith:
We have reviewed your May 6, 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 April 23,
2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Cryptocurrency Hosting Revenue, page 94
1.We continue to evaluate your response to prior comments 2 through 4 from our April 23,
2024 letter.
Form 8-K, Furnished April 25, 2024
Exhibit 99.1
Use and Reconciliation of Non-GAAP Financial Measures, page 3
2.We acknowledge your response to prior comment 5 of our February 21, 2024 letter, and
we note your revised presentation of non-GAAP Adjusted EBITDA in your 8-K furnished
April 25, 2024. Please tell us your consideration of revising the presentation of your non-
GAAP Adjusted EBITDA for periods prior to the adoption of ASU 2023-08.
FirstName LastNameMatthew J. Smith
Comapany NameStronghold Digital Mining, Inc.
May 28, 2024 Page 2
FirstName LastName
Matthew J. Smith
Stronghold Digital Mining, Inc.
May 28, 2024
Page 2
Please contact Rolf Sundwall at 202-551-3105 or Bonnie Baynes at 202-551-4924 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets