SecProbe.io

October 18, 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
Response dated September 25, 2024
File No. 001-40931
Dear Matthew J. Smith:
            We have reviewed your September 25, 2024 response to our comment 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 September 19, 2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 1 - Basis of Presentation and Significant Accounting Policies
Cryptocurrency Hosting Revenue, page 94
1.We do not believe your statement that you have adopted a new accounting policy for
noncash consideration effective July 1, 2024 complies with the requirements for error
correction in ASC 250-10-45-23 and SAB 108. Please reconsider this statement and
tell us how you will correct the errors in accordance with the guidance applicable to
error corrections.
2.Please tell us how you determined the corrected ASC 606 transaction price for each
hosting contract. Where helpful to an understanding, include specific citation(s) to
ASC 606.

October 18, 2024
Page 2
3.Please revise your proposed cryptocurrency hosting revenue accounting policy to
address the following points:
•Reorganize your disclosure to separately describe the promises, the performance
obligation, the consideration, the transaction price, and your timing of
recognition, including contract duration.
•The statement that hosting services consist of electrical power and internet access
appears to be inaccurate. For example, in your May 6, 2024 response letter, you
indicated that Stronghold promises to unload, install, provision, maintain and
operate customer-controlled bitcoin mining machines located at your premises,
including the provision of electrical power, internet access, racking infrastructure,
general maintenance and operations, ambient cooling, and miner reboots for such
mining machines.
•State your May 6, 2024 conclusion that each such promise is not separately
identifiable from the other promises in the contract and therefore represents a
single performance obligation to provide an integrated hosting service.
•Consolidate the various statements about consideration into a single, cohesive
disclosure. For example, remove the statement from the first paragraph that
indicates the consideration for such integrated hosting service is limited to a stated
amount per MWh; remove the reference to “earned” in the description of
consideration so as to avoid confusion with your disclosure about recognition; and
clarify that the statement “the Company’s portion of the Bitcoin mined” means
that you are entitled to a portion of the Bitcoin mined by your customers’ mining
machines that you host.
•Clarify what the transaction price is and how you determined it (see e.g., ASC
606-10-32-8.) Include the disclosure required by ASC 606-10-50-20. Also, revise
the statement that, “The Company recognizes cryptocurrency hosting revenue to
the extent that a significant reversal of such revenue will not occur,” to be
consistent with the requirements of ASC 606-10-32-11 through 32-13, and clarify
whether you are applying the constraint.
•Clarify your method for measuring progress toward complete satisfaction of your
performance obligation (see e.g, ASC 606-10-25-31 to 25-37.)  Also, make the
disclosure required by ASC 606-10-50-18. In your response, tell us whether you
use the practical expedient in ASC 606-10-55-18 to measure progress towards
satisfying your performance obligation, and if so, explain to us why you believe
that practical expedient applies.
•State, if true, that the contracts have a two-year term, neither the Company nor the
customer can cancel or terminate the hosting agreements without penalty before
the two-year term elapses, and therefore you have concluded that the accounting
duration of the contract is two years.
•Describe the renewal options and clarify in disclosure and for us whether they are
material rights. For example, the consideration is not limited to a stated amount
per MWh, but also includes a portion of bitcoin mined by your customers’ mining
machines.
•Make the disclosure required by ASC 606-10-50-8, 50-13, 50-17 and 50-18.

October 18, 2024
Page 3
            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