SecProbe.io

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 June 4, 2025

Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005

 Re: Bullish
 Amendment No. 3 to
 Draft Registration Statement on Form F-1
 Submitted May 21, 2025
 CIK No. 0001872195
Dear Thomas W. Farley:

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

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 14, 2025 letter.

Amendment No. 3 to Draft Registration Statement on Form F-1
Summary Consolidated Financial and Other Data, page 22

1. We note that you present net income/(loss) attributable to owners and
non-controlling
 interests on the top of page 23, but the amounts presented for 2024 are
those related to
 total comprehensive income. Please revise your presentation to present
the appropriate
 net income amount.
 June 4, 2025
Page 2
Capitalization, page 116

2. Please revise your presentation to include your debt in total
capitalization. See Item
 3B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Digital Assets held - intangible assets, inventories and financial assets, page
165

3. In footnote (ii) to the tables on pages 165 and 166 you indicate that
the BTC and ETH
 quantities presented include wrapped tokens such as wBTC and weETH. In
Note 2.8
 on page F-22 you indicate that you derecognize digital assets
transferred to smart
 contracts and recognize the protocol-specific digital assets received in
return. In your
 response, please tell us the amounts of these wrapped token along with
your
 consideration for separately disclosing the quantities and specific
wrapped tokens
 included in your tables given that wrapped tokens present additional
risks to the
 tokens underlying them.
Certain Relationships and Related Party Transactions
Loan Agreement with SPV KY Limited, page 189

4. Please clarify why the reference to "block.one" is deleted from the
first sentence of
 this section.
Consolidated Statements of Cash Flows, page F-8

5. We note approximately $5.6 billion each of non-cash purchases of and
non-cash
 proceeds from disposals of digital assets held - intangible assets as
disclosed at the
 bottom of page F-9. Please tell us the nature of these transactions and
quantify for us
 the significant types of transaction underlying these amounts.
Notes to the Consolidated Financial Statements
Note 12. Taxation
(b) Reconciliation between tax expense and accounting loss at applicable tax
rates, page F-46

6. We note that the $4.2 million "Others" reconciling item in the table for
2024
 represents about 84% of your recorded $5.0 million income tax expense.
Please tell us
 the nature of the tax attributes underlying your "Others" reconciling
item and tell us
 your consideration for separately identifying and disclosing any
material individual
 amounts.
Note 29. Financial risk management
(c) Digital asset risk
(i) Risks with respect to customers' digital assets, page F-67

7. In the first paragraph on page F-68 you reference Note 13(c) which does
not appear to
 exist. Please tell us whether you have customer segregated inventory at
either
 December 31, 2024 or 2023. Otherwise, tell us where you have disclosed
these
 amounts.
 June 4, 2025
Page 3

 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at
202-551-3855
if you have questions regarding comments on the financial statements and
related matters.
Please contact David Gessert at 202-551-2326 or J. Nolan McWilliams at
202-551-3217 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Erin E. Martin
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