SecProbe.io

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 May 14, 2025

Calla Zhao
Chief Financial Officer
BitFuFu Inc.
9 Temasek Boulevard
Suntec Tower 2, #13-01
Singapore 038989

 Re: BitFuFu Inc.
 Form 20-F for Fiscal Year Ended December 31, 2024
 File No. 001-41972
Dear Calla Zhao:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for Fiscal Year Ended December 31, 2024
Notes to the Consolidated Financial Statements
Note 2: Summary of Significant Accounting Policies
Digital assets, page F-11

1. You disclose that you hold digital assets for long-term price
appreciation and plan to
 sell them to support operations as needed and that you classify
purchases and sales of
 digital assets for fiat currency as investing activities. During your
earnings call for the
 fourth quarter of 2024 held on March 25, 2025 we note that you indicated
that your
 general treasury policy is to sell a portion of your mined bitcoins on a
daily basis to
 cover your electricity and hosting costs. Given your adoption of ASU
2023-08 on
 January 1, 2024, please tell us:
 Your consideration for classifying proceeds from sales of your mined
bitcoin to
 cover your electricity and hosting costs as operating activities
under the guidance
 in ASC 230-10-45-27A. In your response, please clarify for us
whether bitcoin
 sold to cover electricity and hosting costs is sold "nearly
immediately" after
 May 14, 2025
Page 2

 acquisition, as that phrase is contemplated under ASC Topic
230-10-45-27A.
 Your consideration for clarifying your general treasury policy in
the Liquidity and
 Capital Resources disclosure of Item 5 and in your financial
statement footnotes.
Revenue recognition
Cloud mining solutions, page F-16

2. We note your disclosure in the second bullet on page F-17 that you act
as principal
 and record the sale of cloud-mining services gross, yet we note no
indication in the
 description of costs of revenue on page F-20 that your costs include the
portion of
 bitcoin mined and distributed to your customer. Please clarify for us
whether you are
 principal in the sales of hash calculations to the mining pool. If so,
tell us the basis for
 your accounting. If not, represent to us that in future filings, you
will revise your
 disclosure to clarify that the principal relationship you previously
discuss results in the
 gross up of your mining equipment costs and that you will specifically
address the
 relationship between your customer and the mining pools they select.
 In closing, 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.

 Please contact Kate Tillan at 202-551-3604 or Mark Brunhofer at
202-551-3638 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
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