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    Bitdeer Technologies Group

    08 Kallang Avenue

    Aperia tower 1, #09-03/04

    Singapore 339509

    October 25, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Crypto Assets

    100 F Street, N.E.

    Washington, D.C. 20549

          Attn:
          Kate Tillan

          David Irving

          Re:

            Bitdeer Technologies Group (the “Company”)

          Form 20-F for the Fiscal Year Ended December 31, 2023

          Filed March 28, 2024

              File No. 001-41687

    Ladies and Gentlemen:

    This letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter dated September 13, 2024 (the “Comment Letter”), relating to the above referenced Form 20-F (the
      “Form 20-F”). The Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used but not defined herein are used herein as defined in the
      Form 20-F.

    Form 20-F for the Fiscal Year Ended December 31, 2023

    Item 5. Operating and Financial Review and Prospects

    Non-IFRS Financial Measures, page 77

          1.

            Please revise your future filing disclosure to provide your discussion of Profit/(loss) for the year/period before your disclosures of the Adjusted EBITDA and Adjusted Profit. The IFRS amounts should be presented
              with equal or greater prominence than non-IFRS measures. Specifically, we note the non-IFRS disclosures are included on pages 77-78 before the IFRS measures, which are discussed in the Results of Operations section on pages 85-93. Refer to
              Question 102.10(a) of the Non-GAAP Compliance and Disclosure Interpretations.

    The Company respectfully acknowledges the Staff’s comment and advises the Staff that in future filings, including the Company’s Form 20-F that contain non-IFRS measures, the Company will present IFRS amounts with equal
      or greater prominence than non-IFRS measures in accordance with Question 102.10(a) of the Non-GAAP Compliance and Disclosure Interpretations.

    Financial Statements

    Note 2. Summary of Significant Accounting Policies

    (q) Revenue recognition

    Self-mining, page F-21

                October 25, 2024

                Page 2

          2.

            Please respond to the following and revise your disclosure in future filings as necessary to address the following concerning your revenue recognition under IFRS 15:

          •

            Tell us and disclose the payment mechanism(s) used by your mining pools (for example, FPPS, PPLNS, etc.).

          •

            Disclose, if true, that you consider the mining pool operators to be your customers and you decide when to provide services under the contracts.

          •

            You disclose that the contracts with mining pool operators are terminable at any time by either party. Clarify whether or not your contracts are terminable at any time by either party without penalty. If they
              are, revise your disclosure accordingly and tell us your consideration for whether, as a result of the termination rights, the mining pool agreement is continuously renewed for accounting purposes and the accounting duration of your contracts
              is less than 24 hours. If true, tell us your consideration of disclosing that your enforceable right to compensation only begins when, and continues as long as, you provide hash computation services to the mining pools, the duration of the
              contract is less than 24 hours and the contract continuously renews throughout the day.

          •

            Assuming you conclude that your contracts are continually renewed, tell us whether you determined that the mining pool operator’s implied renewal option is not a material right as the terms, conditions, and
              compensation amounts are at then market rates. Refer to Appendix B40 of IFRS 15.

          •

            You disclose that your only performance obligation is providing computing power. Tell us whether a more accurate description of your promise is a service to perform hash calculations for the pool operator, and if
              so, make corresponding revisions in future filings to your accounting policy and related disclosures.

          •

            Disclose how payments are generally calculated, including the various components of the payment (for example, block reward, transaction fees, less pool operator fee) and the period over which the computations
              take place (for example, generally midnight to midnight UTC). Also disclose the nature of the non-cash consideration received (for example, bitcoin).

          •

            You disclose that the Group recognizes the revenue when the variable consideration is reasonably estimable and the performance obligation of providing computing power has been satisfied. Disclose whether revenue
              is recognized on the same day that control of the contracted service transfers to the mining pool operator. Refer to IFRS 15.31.

          •

            Clarify for us, by way of example, when and how you determine the amount of revenue to recognize each day for the non-cash consideration received and revise your disclosure to clarify the timing and method of
              valuing the non-cash consideration received.

    The Company acknowledges the Staff’s comments and advises the Staff the following, with respect to each of the bullet points above:

          •

            Tell us and disclose the payment mechanism(s) used by your mining pools (for example, FPPS, PPLNS, etc.).

    The Company respectfully advises the Staff that 99.6%, 98.8%, 96.1% and 96.9% of its self-mining revenue for the six months ended June 30, 2024 and for the years ended December 31, 2023, 2022 and 2021, respectively, were
      generated from Bitcoin mining. For the six months ended June 30, 2024 and for the years ended December 31, 2023, 2022, 2021, the Bitcoin mining revenue generated from mining pools by payment mechanisms is as follows:

                Payment mechanism

                For the six

                months ended

                June 30, 2024

                For the year

                ended December

                31, 2023

                For the year

                ended December

                31, 2022

                For the year

                ended December

                31, 2021

              (In thousands of US$)

              FPPS

              68,146

              83,462

              59,617

              185,290

              PPS+

              21,543

              26,924

              228

              366

    Please refer to Exhibit A for the proposed disclosures.

                October 25, 2024

                Page 3

          •

            Disclose, if true, that you consider the mining pool operators to be your customers and you decide when to provide services under the contracts.

    The Company respectfully advises the Staff that while the Company can decide when to start or stop providing the services, in terms of contract termination, both the Company and the mining pool operator have the
      unilateral right to terminate the contract without compensating the other party. In other words, the mining pool operator also has the right to terminate the contract (i.e., stop the Company’s services) based on the contract. Please refer to Exhibit A for the proposed disclosures.

          •

            You disclose that the contracts with mining pool operators are terminable at any time by either party. Clarify whether or not your contracts are terminable at any time by either party without penalty. If they
              are, revise your disclosure accordingly and tell us your consideration for whether, as a result of the termination rights, the mining pool agreement is continuously renewed for accounting purposes and the accounting duration of your contracts
              is less than 24 hours. If true, tell us your consideration of disclosing that your enforceable right to compensation only begins when, and continues as long as, you provide hash computation services to the mining pools, the duration of the
              contract is less than 24 hours and the contract continuously renews throughout the day.

    The Company respectfully clarifies that the contracts with mining pool operators are terminable at any time by either party without penalty.

    The Company assesses and determines whether, as a result of the termination rights, the mining pool agreement is continuously renewed for accounting purposes and the accounting duration of the contracts is less than 24
      hours. As self-mining is one of the Company’s primary business operations, the Company participates in the mining pool and provides hash calculation service to the pool operators continuously. The mining pools determine mining rewards to pool
      participants on a daily basis. Based on these practices, the Company believes that it has a present enforceable right to collect the payment, and the mining pool has a present enforceable obligation to make the payment, in a given day, and that the
      contract duration is less than 24 hours and continuously renewed throughout the day.

    Based on the analysis above, the Company determines that as a result of the termination rights, the Company’s enforceable right to compensation only begins when, and continues as long as, the Company provides hash
      calculation services to the mining pools, the duration of the contract is less than 24 hours and the contract continuously renews throughout the day. The disclosure in future filings will be revised accordingly. Please refer to Exhibit A for the proposed disclosures.

          •

            Assuming you conclude that your contracts are continually renewed, tell us whether you determined that the mining pool operator’s implied renewal option is not a material right as the terms, conditions, and
              compensation amounts are at then market rates. Refer to Appendix B40 of IFRS 15.

    The Company respectfully clarifies that after disconnecting the mining machine to the mining pool proxy (i.e., terminating the existing contract), the Company could always reconnect the mining machine to the mining pool
      proxy, and receive mining yield from the mining pool operator under the same payment mechanism, which is considered at the then market rates. In this case, the Company believes the termination provision is similar to a renewal option. However, since
      the Company receives mining yields based on a universal payment mechanism, and the mining pool operator does not provide the Company with any goods or services, or alter any payment mechanisms to induce such renewal, the renewal is not considered a
      material right according to IFRS 15 B40.

          •

            You disclose that your only performance obligation is providing computing power. Tell us whether a more accurate description of your promise is a service to perform hash calculations for the pool operator, and
              if so, make corresponding revisions in future filings to your accounting policy and related disclosures.

    The Company acknowledges the Staff’s comment and advises the Staff that the disclosure in future filings will be revised accordingly to further clarify the performance obligation of the arrangement. Please refer to Exhibit A for the proposed disclosures.

                October 25, 2024

                Page 4

          •

            Disclose how payments are generally calculated, including the various components of the payment (for example, block reward, transaction fees, less pool operator fee) and the period over which the computations
              take place (for example, generally midnight to midnight UTC). Also disclose the nature of the non-cash consideration received (for example, bitcoin).

    The Company acknowledges the Staff’s comment and advises the Staff that the disclosure in future filings will be revised accordingly. Please refer to Exhibit A for the
      proposed disclosures.

          •

            You disclose that the Group recognizes the revenue when the variable consideration is reasonably estimable and the performance obligation of providing computing power has been satisfied. Disclose whether revenue
              is recognized on the same day that control of the contracted service transfers to the mining pool operator. Refer to IFRS 15.31.

    The Company acknowledges the Staff’s comment and advises the Staff that the disclosure in future filings will be revised to clarify that the revenue is recognized on the same day that control of the contracted service
      transfers to the mining pool operator. Please refer to Exhibit A for the proposed disclosures.

          •

            Clarify for us, by way of example, when and how you determine the amount of revenue to recognize each day for the non-cash consideration received and revise your disclosure to clarify the timing and method of
              valuing the non-cash consideration received.

     The Company respectfully clarifies that as the Company generates self-mining revenue solely from participating third-party mining pools, the quantity of non-cash consideration is determined primarily based on the
      quantity of hash rate contributed to the mining pool in providing the hash calculation for the mining pool (in calculating the block reward). The Company has the ability to estimate the quantity of non-cash consideration based on the contractual
      formula when the Company begins to provide the hash calculation service and recognizes revenue on the same day that control of the contracted service transfers to the mining pool operator.

    The Company uses the price at 0:00:00 UTC of a given day to estimate the non-cash consideration the Company is entitled to for service provided in that day. The Company believes it is an appropriate approach to be used
      under IFRS 15 and has been applying this valuation method consistently historically.

    The Company advises the Staff that the disclosure in future filings will be revised to clarify the timing and method of valuing the non-cash consideration received. Please refer to Exhibit

          A for the proposed disclosures.

    Note 3. Use Of Judgments and Estimates, page F-33

          3.

            We note your disclosure on pages 28, 37, 38, and F-33 that, “there is currently no specific definitive guidance in IFRS or alternative accounting frameworks for the accounting for the revenue from the self-mining
              business.” We are unclear how these statements are consistent with management’s responsibility to provide financial statements it asserts are compliant with IFRS as issued by the IASB. In that regard, we observe that the IFRS accounting
              standards are the source of authoritative generally accepted accounting principles and that there is guidance whose scope applies to your transactions. Please revise future filings to remove this disclosure.

    The Company respectfully acknowledges the Staff’s comment and advises the Staff that the disclosure to which this comment relates will be removed from future filings.

    *          *          *

                October 25, 2024

                Page 5

    If you have any questions regarding the response letter, please contact the Company’s U.S. counsel Will H. Cai of Cooley LLP by phone at +852-3758-1210 or via e-mail at wcai@cooley.com.

            Very truly yours,

            /s/ Jihan Wu

            Jihan Wu

            Chairman of the Board and Chief Executive Officer

          cc:

            Linghui Kong, Chief Business