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February 8, 2023
Linghui Kong
Chief Executive Officer
Bitdeer Technologies Group
08 Kallang Avenue
Aperia Tower 1, #09-03/04
Singapore 339509
Re:Bitdeer Technologies Group
Amendment No. 10 to Draft Registration Statement on Form F-4
Submitted February 03, 2023
CIK No. 0001899123
Dear Linghui Kong:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 31, 2023 letter.
Amendment No. 10 to Draft Registration Statement on Form F-4
Information Related to Bitdeer
Energy, page 212
1.We note your response to prior comment 5 and reissue it, in part. In light of the
importance of energy to your operations, please provide detail about the production
of energy used at your mining datacenters.  For example, discuss whether the power
suppliers at each of your datacenters are coal-fired plants or hydroelectric facilities.
Bitdeer's Directors and Executive Officers, page 215
2.Update your total compensation paid and benefits in-kind provided to your directors and

 FirstName LastNameLinghui Kong
 Comapany NameBitdeer Technologies Group
 February 8, 2023 Page 2
 FirstName LastName
Linghui Kong
Bitdeer Technologies Group
February 8, 2023
Page 2
executive officers for the year ended December 31, 2022.
Bitdeer Technologies Holding Company and Subsidiaries
Notes to the Unaudited Condensed Consolidated Financial Statements
Note 20. Related Party Transactions, page F-58
3.We continue to consider your responses to comment 3 in your letter dated September 6,
2022, to comments 2 and 3 in your letter dated November 3, 2022, and to comment 7 in
your letter dated November 23, 2022, in addition to your letter dated December 21, 2022,
regarding your accounting for cryptocurrency lending transactions and wealth
management products and may have further comment.
General
4.We note mention of Genesis Mining and Power Mining Pool on page 80 in your filing.
Please disclose whether you or Matrixport have any direct or indirect relationship with
either company.
            You may contact Melissa Walsh, Senior Staff Accountant, at (202) 551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters.  Please contact Kyle Wiley, Staff
Attorney, at (202) 344-5791 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Will Cai