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March 1, 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. 11 to Draft Registration Statement on Form F-4
Submitted February 10, 2023
CIK No. 0001899123
Dear Linghui Kong:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our 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 comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 11 to Draft Registration Statement on Form F-4
Risk Factors, page 42
1.Please provide risk factor disclosure clarifying that, based on the relevant facts as they
exist today, Zcash may be a security under the federal securities laws.

 FirstName LastNameLinghui Kong
 Comapany NameBitdeer Technologies Group
 March 1, 2023 Page 2
 FirstName LastName
Linghui Kong
Bitdeer Technologies Group
March 1, 2023
Page 2
            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