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March 16, 2023
Linghui Kong
Chief Executive Officer
Bitdeer Technologies Group
08 Kallang Avenue
Aperia Tower 1, #09-03/04
Singapore 339509
Re:Bitdeer Technologies Group
Registration Statement on Form F-4
Filed March 8, 2023
File No. 333-270345
Dear Linghui Kong:
            We have reviewed your 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.
Registration Statement on Form F-4 filed March 8, 2023
BSGA's Board's Review of Valuation, page 135
1.We note your non-reliance on your outdated projections and your consideration of certain
selected financial information to support a revised valuation of Bitdeer.  In this regard,
explain how the significant drop in the valuation of Bitdeer ($4.5 billion reduced to $1.18
billion) provided the Board an "adequate basis" to support consummation of the merger.

 FirstName LastNameLinghui Kong
 Comapany NameBitdeer Technologies Group
 March 16, 2023 Page 2
 FirstName LastName
Linghui Kong
Bitdeer Technologies Group
March 16, 2023
Page 2
BSGA's Management's Discussion and Analysis of Financial Condition and Results of
Operation, page 190
2.Please revise to update the discussion indicating that you have not selected any specific
business combination target.
Critical Accounting Policies
Net Income per Common Share, page 194
3.Please revise to explain how the estimation uncertainties impact your computation of net
loss per share.
Bitdeer's Management's Discussion and Analysis of Financial Condition and Results of
Operation, page 220
4.We note the selected unaudited financial information for the year ended December 31,
2022 disclosed on page 142.  Tell us what consideration you gave to discussing and
analyzing your preliminary results, with disclosure addressing whether such results reflect
trends consistent with your historical results, and why only preliminary financial
information is available.  Also consider disclosing such information in the forepart of the
filing.
Experts, page 272
5.We note that you have also included audited financial statements of Blue Safari Group
Acquisition Corp. as of December 31, 2022.  Revise to update the disclosure regarding the
statement of experts.  Refer to Item 10.G of Form 20-F.
Annex D: Valuation Reports of Royson Valuation Advisory Limited, page D-1
6.Please include Royson's updated Valuation Report supporting the revised valuation of
Bitdeer.
Exhibit 99.10, page II-2
7.The representation included as Exhibit 99.10 indicates that the registration statement on
Form F-4 relates to the proposed initial public offering in the United States of the
Company’s ordinary shares to be represented by American depositary shares in
connection with the business combination.  However, we note that, pursuant to the Third
Amendment, the parties agreed to remove the American Depository Share structure
previously contemplated under the Second Amended Merger Agreement and instead issue
ordinary shares of BTG as considerations to be paid.  Please revise the description of the
registration statement in your representation, accordingly.

 FirstName LastNameLinghui Kong
 Comapany NameBitdeer Technologies Group
 March 16, 2023 Page 3
 FirstName LastName
Linghui Kong
Bitdeer Technologies Group
March 16, 2023
Page 3
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            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