SecProbe.io

CORRESP
 1
 filename1.htm

 August 11, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance

 100 F Street, N.E.
Washington, D.C. 20549

 Attn:
 David Gessert

 J. Nolan McWilliams

 Re:
 Bullish

 Acceleration
 Request for Bullish

 Registration
 Statement on Form F-1

 File No. 333-288780

 Ladies and Gentlemen:

 We refer to the registration statement on Form F-1
(File No. 333-288780) (as amended, the " Registration Statement "), of Bullish (the " Company "),
relating to the registration of the Company's ordinary shares, nominal value $0.002 per share.

 In accordance with Rules 460 and 461 under
the Securities Act of 1933, as amended, (the " Act ") we, as representatives of the several underwriters (the " Underwriters "),
hereby respectfully request that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:00
P.M. (Eastern time) on August 12, 2025, or at such later time as the Company or its counsel may orally request via telephone
call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission.

 Pursuant to Rule 460 under the Act, we, as
representatives of the several underwriters, wish to advise you that we will take reasonable steps to secure adequate distribution of
the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration
Statement.

 We, the undersigned, as representatives of the
several Underwriters, have complied and will comply, and we have been informed by the participating Underwriters that they have complied
and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [ Signature Page Follows ]

 Very
 truly yours,

 J.P. MORGAN SECURITIES LLC JEFFERIES
 LLC

 As representatives of the several
 underwriters

 J.P. MORGAN SECURITIES LLC

 By:
 /s/
Alaoui Zenere

 Name: Alaoui Zenere

 Title: Managing Director

 JEFFERIES LLC

 By:
 /s/ Kevin Lacerda

 Name: Kevin Lacerda

 Title: Managing Director

 [ Signature Page to Acceleration Request ]

CORRESP
 1
 filename1.htm

 Bullish

 10A Building A, 60 Nexus Way, Camana Bay,
George Town, Grand Cayman, Cayman Islands, KY1-9005

 August 11, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: David Gessert, J. Nolan McWilliams

 Re: Bullish
 Registration Statement on Form F-1
 File No. 333-288780

 Ladies and Gentlemen:

 In accordance with Rule 461 under the
Securities Act of 1933, as amended, Bullish (the "Registrant") respectfully requests that the effective date of the
above-referenced Registration Statement on Form F-1 (as amended, the "Registration Statement") be accelerated so that the same will
become effective at 4:00 PM ET on August 12, 2025, or as soon thereafter as is practicable. By separate letter, the underwriters for the offering to which the Registration Statement relates join in this request for acceleration.

 The Registrant hereby authorizes Howard A. Kenny
and Erin E. Martin, of Morgan, Lewis & Bockius LLP to orally modify or withdraw this request for acceleration.

 Please contact Howard A. Kenny at +1.212.309.6843
or howard.kenny@morganlewis.com or Erin E. Martin at +1.202.739.5729 or erin.martin@morganlewis.com with any questions you may have concerning
this request, and please notify them when this request for acceleration has been granted.

 Very truly yours,

 Bullish

 By:
 /s/ Thomas W. Farley

 Name:
 Thomas W. Farley

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 July 29, 2025

 Howard Kenny

 212-309-6843

 Howard.Kenny@morganlewis.com

 Erin E. Martin

 202-739-5729

 Erin.Martin@morganlewis.com

 SENT VIA EMAIL

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Crypto Assets

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 Mark Brunhofer, Jason Niethamer, David Gessert and J. Nolan
 McWilliams

 Re:
 Bullish Registration Statement on Form F-1 (File No. 333-288780)

 Submission of Supplemental Materials

 Ladies and Gentlemen:

 On behalf of Bullish (the " Company "), enclosed
herewith kindly find the attached supplemental materials (collectively, the " Supplemental Materials "), which include
draft disclosure for illustrative purposes, for the Staff's review with respect to the Company's Registration Statement on
Form F-1(File No. 333-288780) (the " Registration Statement ").

 Should the Staff have additional questions or comments, please do
not hesitate to contact the undersigned at (202) 739-5729 or Howard A. Kenny at (212) 309-6843.

 Sincerely,

 /s/ Erin E. Martin

 Morgan, Lewis & Bockius LLP

 101 Park Avenue

 New York, NY 10178-0060
 +1.212.309.6000

 United States
 +1.212.309.6001

 Recent Developments

 Selected Preliminary
Estimated Condensed Financial Results as of and for the Three Months Ended June 30, 2025

 Set forth
below are selected unaudited and unreviewed preliminary results and estimates of our condensed consolidated financial results as of and
for the three months ended June 30, 2025, and actual financial results derived from our unaudited interim condensed consolidated
statements of operations for the three months ended June 30, 2024. Our unaudited interim consolidated financial statements as of
and for the three months ended June 30, 2025 are not yet complete due to the completion of our financial closing and other operational
procedures, final adjustments, and other developments that may arise between now and the time such financial statements are finalized.
Accordingly, we have only provided partial and preliminary financial information, or in certain cases, estimated ranges rather than specific
amounts for the preliminary results as of and for the three months ended June 30, 2025 set forth below. Our final reported results
may vary from the preliminary estimates and, accordingly, undue reliance should not be placed on these preliminary estimates. The following
preliminary unaudited consolidated financial information regarding our performance and financial condition as of and for the three months
ended June 30, 2025 reflect our management's best estimate of the results as of and for the three months ended June 30,
2025, and are based on the information available to us as of the date of this prospectus. Our actual unaudited consolidated financial
statements as of and for the three months ended June 30, 2025, and June 30, 2024, are not expected to be filed with the Securities
and Exchange Commission until after the completion of this offering.

 The preliminary
estimated financial results should not be considered a substitute for full financial statements as of and for the three months ended
June 30, 2025, prepared in accordance with IFRS. The estimated and actual results presented below are not necessarily indicative
of any future period and should be read together with our consolidated financial statements and related notes included elsewhere in this
prospectus. See the sections entitled "Cautionary Note Regarding Forward-Looking Statements," "Risk Factors,"
 and "Management's Discussion and Analysis of Financial Condition and Results of Operations" for additional
information regarding factors that could result in differences between the preliminary estimates of our financial results presented below
and the financial results we will report as of and for the three months ended June 30, 2025.

 Certain
of the preliminary estimates of and actual financial results presented below are financial measures that are not recognized by IFRS and
that may not be permitted to appear on the face of IFRS- compliant financial statements or notes thereto. These non-IFRS financial measures
are "adjusted transaction revenue," "adjusted revenue," "adjusted net income (loss)" and "adjusted
EBITDA." For a discussion of these measures and the limitations to the use of the non-IFRS financial measures presented in this
prospectus, see section entitled " Management's Discussion & Analysis of Financial Condition and Results of Operations
 - Non-IFRS Financial Measures ." We also present an estimate of "gross liquid assets" and "net liquid
assets" as of June 30, 2025, non-IFRS measures discussed in more detail below.

 2

 The preliminary
estimated financial results as of and for the three months ended June 30, 2025, have been prepared by, and are the responsibility
of, our management. Our independent registered public accounting firm, Deloitte & Touche LLP, has not audited, reviewed, compiled
or performed any procedures with respect to this preliminary financial information and, accordingly, Deloitte & Touche LLP does
not express an opinion or any other form of assurance with respect thereto.

 Three
 months ended June 30,

 2025

 Total
 2024

 US$ million s
 Total

 Estimated
 US$ millions

 High
 Low
 Actual

 Digital assets sales
 $ 58,630.6
 $ 58,630.6
 $ 49,578.2

 Cost of digital assets derecognized
 (58,615.3 )
 (58,615.3 )
 (49,556.5 )

 Other revenues
 32.3
 31.3
 25.0

 Change in fair value of digital assets held, net
 68.4
 68.4
 (99.4 )

 Net spread related income and change in fair value of perpetual
 futures
 (2.0 )
 (2.0 )
 (4.8 )

 Change in fair value of investments in financial assets
 86.4
 86.4
 (0.7 )

 Administrative expenses
 (43.0 )
 (43.0 )
 (39.7 )

 Other expenses
 (17.4 )
 (17.4 )
 (16.6 )

 Finance expenses
 (13.3 )
 (13.3 )
 (9.1 )

 Change in fair value of derivatives
 (2.4 )
 (2.4 )
 0.2

 Change in fair value of financial liability
 at FVTPL
 (15.3 )
 (15.3 )
 6.1

 Income/(loss) before income tax
 $ 109.1
 $ 108.1
 $ (117.2 )

 Income tax expense
 (0.9 )
 (0.9 )
 (0.3 )

 Net income/(loss)
 $ 108.3
 $ 107.3
 $ (117.5 )

 For the
three months ended June 30, 2025, we expect Digital asset sales to be $58,630.6 million and Cost of digital assets derecognized
to be $(58,615.3) million, as compared to $49,578.2 million and $(49,556.5) million, respectively, for the three months ended June 30,
2024, driven primarily by increased trading on the Exchange.

 For the
three months ended June 30, 2025, we expect Other revenues to be in the range of $32.3 million and $31.3 million, as compared with
$25.0 million for the three months ended June 30, 2024, driven primarily by increase network solutions revenue.

 For the
three months ended June 30, 2025, we expect Change in fair value of digital assets held, net to be $68.4 million, as compared to
$(99.4) million for the three months ended June 30, 2024, driven primarily by mark-to market adjustments.

 For the
three months ended June 30, 2025, we expect Net income/(loss) to be between $108.3 million and $107.3 million, as compared to Net
income/(loss) of ($117.5) million for the three months ended June 30, 2024. The expected increase is primarily driven by favorable
changes in fair value of digital assets held and investments in financial assets.

 3

 Adjusted
transaction revenue, Adjusted revenue, Adjusted net income, and Adjusted EBITDA are non-IFRS financial metrics. For more information
regarding our use of these metrics and their usefulness to investors, including the limitations of their use, see "Management's
Discussion and Analysis of Financial Condition and Results of Operations - Non-IFRS Financial Measures." The following tables
present condensed consolidated statements of profit and loss and reconciliations of the aforementioned non-IFRS metrics to their most
directly comparable IFRS financial metrics for the periods presented:

 Three
 months ended June 30,

 2025

 Total
 2024

 US$ million s
 Total

 Estimated
 US$ millions

 High
 Low
 Actual

 Non-IFRS Financial Measures

 Adjusted transaction revenue
 $ 24.1
 $ 24.1
 $ 34.9

 Adjusted revenue
 $ 57.0
 $ 56.0
 $ 60.7

 Adjusted net income
 $ (6.0 )
 $ (7.0 )
 $ 4.9

 Adjusted EBITDA
 $ 8.1
 $ 7.1
 $ 14.8

 For the
three months ended June 30, 2025, we expect Adjusted transaction revenue to be $24.1 million, as compared to Adjusted transaction
revenue of $34.9 million for the three months ended June 30, 2024. The expected decrease is primarily driven by lower trading spreads,
which is the difference between digital asset sales and cost of digital assets derecognized.

 For
the three months ended June 30, 2025, we expect Adjusted revenue to be between $57.0 million and $56.0 million, as compared to
Adjusted revenue of $60.7 million for the three months ended June 30, 2024. The expected decrease is primarily driven by
decreased Adjusted transaction revenue, partially offset by increases in subscription and services revenue.

 For the
three months ended June 30, 2025, we expect Adjusted net income to be between ($6.0) million and ($7.0) million, as compared to
Adjusted net income of $4.9 million for the three months ended June 30, 2024. The expected decrease is primarily driven by lower
trading spreads and increased administrative expenses.

 For
the three months ended June 30, 2025, we expect Adjusted EBITDA to be between $8.1 million and $7.1 million, as compared to
Adjusted EBITDA of $14.8 million for the three months ended June 30, 2024. The expected decrease is primarily driven by
decreased trading spreads and higher administrative expenses, partially offset by increases in subscription and services
revenue.

 Three
 months ended June 30,

 2025

 Total
 2024

 US$ million s
 Total

 Estimated
 US$ millions

 High
 Low
 Actual

 Digital assets sales
 $
 58,630.6
 $
 58,630.6
 $
 49,578.2

 Digital
 asset sales on venues other than Exchange
 (30.1 )
 (30.1 )
 (8.8 )

 Digital assets sales – on our
 Exchange
 58,600.6
 58,600.6
 49,569.4

 Cost of digital assets derecognized
 – on our Exchange
 (58,585.1 )
 (58,585.1 )
 (49,547.6 )

 Change in fair
 value of digital assets inventories, arising from purchase of digital assets on our Exchange
 10.2
 10.2
 17.5

 Transaction income
 0.4
 0.4
 0.4

 Net spread related income and change
 in fair value of perpetual futures
 (2.0 )
 (2.0 )
 (4.8 )

 Adjusted Transaction Revenue
 $ 24.1
 $ 24.1
 $ 34.9

 Subscriptions and services revenue
 31.9
 30.9
 24.6

 Change in fair value of investment
 in financial assets
 -
 -
 -

 Revaluation of
 digital assets held as investments
 1.0
 1.0
 1.2

 Adjusted Revenue
 $ 57.0
 $ 56.0
 $ 60.7

 Income/(loss)
 $ 108.3
 $ 107.3
 $ (117.5 )

 Adjusted to exclude the following:

 Digital asset sales on other venues
 (30.1 )
 (30.1 )
 (8.8 )

 Cost of digital assets derecognized
 on other venues
 30.2
 30.2
 8.9

 4

 Three
 months ended June 30,

 2025

 Total
 2024

 US$ million s
 Total

 Estimated
 US$ millions

 High
 Low
 Actual

 Loss/(Gain) from changes in fair value
 of digital assets inventories net payable
 to customers
 (25.8 )
 (25.8 )
 104.6

 Income tax expense
 0.9
 0.9
 0.3

 Finance expenses
 13.3
 13.3
 9.1

 Share-based payment expenses
 3.3
 3.3
 8.9

 Change in fair
 value of loan and other receivables – digital assets
 (39.2 )
 (39.2 )
 9.3

 Change in fair value of digital assets
 loan payable
 -
 -
 (1.5 )

 Change in fair value of derivatives
 2.4
 2.4
 (0.2 )

 Change in fair value of financial liability
 at FVTPL
 15.3
 15.3
 (6.1 )

 Change in fair value of investments
 in financial assets
 (86.4 )
 (86.4 )
 0.7

 Impairment losses of digital assets
 held – intangible assets
 6.7
 6.7
 4.5

 Impairment of right-of-use assets
 -
 -
 1.0

 Non-recurring expenses
 7.4
 7.4
 (0.3 )

 Depreciation and amortization
 0.8
 0.8
 0.8

 Adjusted to include the following:

 -

 Revaluation of
 digital assets held as investments
 1.0
 1.0
 1.2

 Adjusted EBITDA
 $ 8.1
 $ 7.1
 $ 14.8

 Finance expenses
 (13.3 )
 (13.3 )
 (9.1 )

 Depreciation and amortization
 (0.8 )
 (0.8 )
 (0.8 )

 Tax effect of
 adjusted net income before taxes
 0.0
 0.0
 0.0

 Adjusted net income / (loss)
 $ (6.0 )
 $ (7.0 )
 $ 4.9

 Set out below are estimated selected
 balance sheet items as of June 30, 2025.

 June 30,
 2025

 (in millions)

 Cash and Cash Equivalents
 35.6

 Digital assets held – inventories
 231.9

 Digital assets held – intangible assets
 1,957.4

 Digital assets held – financial assets
 106.2

 Loan and other receivable – digital assets
 310.9

 Investments in financial assets
 422.5

 Customer segregated cash
 4.2

 Other current assets
 35.1
 – 34.1

 Non-current assets
 135.6

 Total Assets
 3,239.3
 – 3,238.3

 Borrowings from related parties
 496.9

 Convertible redeemable preference shares
 47.9

 Borrowings
 79.6

 Other current liabilities
 52.6

 Other non-current liabilities
 11.1

 Total Liabilities
 688.1

 Total Equity
 2,551.3
 – 2,550.3

 5

 Other
current assets, Non-current assets, Other current liabilities, and Other non-current liabilities are combined with other financial statement
line items from our consolidated financial statements, unless otherwise separately disclosed.

 Digital
assets held - inventories at June 30, 2025 consisted of the following:

 Units
 (in
 thousands)
 Fair Value
 (in thousands)

 Stablecoins

 $ 8,798

 BTC
 1.75
 188,633

 ETH
 10.77
 26,509

 Other

 7,930

 Total

 $ 231,870

 Digital assets
 held - intangible assets at June 30, 2025 consisted of the following:

 Units (in
 thousands)
 Fair Value
 (in thousands)

 Stablecoins

 $ 5,206

 BTC
 17.81
 1,916,538

 ETH
 0.81
 1,922

 Other

 33,735

 Total

 $ 1,957,402

 Digital
assets held - financial assets consist of stablecoins held on our Exchange exclusively for market-making purposes, as well as
stablecoins held off-exchange for other uses. As of June 30, 2025, our holdings of these financial assets consisted of the following:

 Units (in thousands)
 Fair Value
 (in thousands)

 Stablecoins – on Exchange

 $ 76,887

 Stablecoins – off Exchange

 29,362

 Total

 $ 106,249

 Loans and other receivables
 - digital assets at June 30, 2025 consisted of the following:

 Units (in thousands)

 Fair Value
 (in thousands)

 Stablecoins

 $ 25,994

 BTC
 2.61
 281,188

 ETH
 1
 2,558

 Other

 1,188

 Total

 $ 310,927

 Investments in financials assets
at June 30, 2025 consisted of the following:

 Units (in thousands)
 Fair Value
 (in thousands)

 BTC Funds

 2.13
 $ 229,248

 CD20 Funds

 134,412

 Digital assets investment funds

 58,810

 Total

 $ 422,470

 6

 In addition
to measures of liquidity presented in accordance with IFRS, our management evaluates our liquidity by reference to our "gross liquid
assets" and "net liquid assets," which are non-IFRS financial measures. Gross liquid assets is defined as the sum of
(i) digital assets held - inventories, (ii) digital assets held - intangible assets, (iii) digital assets
held -financial assets, and (iv) loans and other receivables-digital assets and investments in financial assets, (v) investments
in financial assets, and (vi) cash and cash equivalents (each of which, as outlined in the below footnotes to the condensed consolidated
balance sheet estimate, is reflected on our balance sheet at fair market value as required, in accordance with IFRS). Net liquid assets
is defined as gross liquid assets, reduced by (i) digital assets held - inventories, (ii) the portion of digital assets
held - financial assets on our Exchange, (iii) borrowings, (iv) other borrowings, and (v) digital assets loan payable.
We believe these non-IFRS measures provide useful information to investors and others in understanding and evaluating our liquidity in
the same manner as management and our board of directors. These measures should not be considered in isolation or as a substitute for
financial information presented in accordance w

CORRESP
 1
 filename1.htm

 July 18, 2025

 VIA EDGAR

 CONFIDENTIAL

 U.S. Securities and Exchange Commission
Division of Corporation Finance

 Office of Crypto Assets
100 F. Street, N.E.

 Washington, D.C. 20549

 Attn: Mark Brunhofer, Jason Niethamer,

   David Gessert and J. Nolan McWilliams

 Re:
 Bullish

 Amendment No. 5 to Draft Registration Statement
 on Form F-1

 Submitted July 7, 2025

 CIK No. 0001872195

 To the addressees set forth above:

 On behalf of our client, Bullish (the "Company"),
we submit this letter in response to comments from the staff (the "Staff") of the U.S. Securities and Exchange Commission
(the "SEC") contained in its letter dated July 16, 2025, relating to the above referenced Amendment No. 5 to Draft Registration
Statement on Form F-1 (the "Draft Registration Statement"). Concurrently herewith, the Company is publicly filing a Registration
Statement on Form F-1 (the "Registration Statement").

 For the Staff's convenience, the Staff's
comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company. Except for any page
references appearing in the headings or the Staff's comments (which are references to the Draft Registration Statement), all page
references herein correspond to the page of the Registration Statement. Capitalized terms used but not defined in this letter have the
meanings ascribed to such terms in the Registration Statement. Where appropriate, changes conforming to those noted in responses have
also been made elsewhere in the prospectus.

 Morgan,
 Lewis & Bockius llp

 101 Park Avenue New York, NY 10178-0060
 +1.212.309.6000

 United States +1.212.309.6001

 Securities and Exchange Commission

 July 18, 2025

 Page 2

 Amendment No. 5 to Draft Registration Statement on Form F-1

 Summary

 Recent Developments, page 20

 1. We note your intention to provide preliminary information in the form of ranges for the three months
ended June 30, 2025. When you update your submission with this preliminary information, please also discuss any trends evident from this
information as well as the underlying causes for changes in amounts compared to the actual amounts provided for the three months ended
June 30, 2024.

 The Company confirms that when
it updates the disclosure to include the preliminary information for the quarter ended June 30, 2025, it will add an appropriate discussion
of any evident trends and key drivers of the changes.

 Management's Discussion and Analysis of Financial Condition and
Results of Operations

 Results of Operations

 Comparison of the three months ended March 31, 2025 and 2024

 Change in fair value of digital assets held, net, page 167

 2. Please revise your disclosure to explain the $142 million impairment losses of digital assets held
- intangible assets. To the extent appropriate, link this disclosure to your other comprehensive income/loss disclosure at the bottom
of page 168.

 In
response to the Staff's comment, the Company has revised the disclosure on page 169 to explain the $142 million impairment losses
of digital assets held - intangible assets and the relation to other comprehensive income/loss.

 Please do not hesitate to contact the undersigned
at +1.212.309.6843 or Erin E. Martin at +1.202.739.5729 with any questions you may have regarding this confidential submission.

 Very truly yours,

 /s/ Howard A. Kenny

 Howard A. Kenny

 cc:
 Nicholas Armstrong, General Counsel, Bullish

 Joseph A. Hall, Davis Polk & Wardwell LLP

 Daniel P. Gibbons, Davis Polk & Wardwell LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 16, 2025

Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005

 Re: Bullish
 Amendment No. 5 to Draft Registration Statement on Form F-1
 Submitted July 7, 2025
 CIK No. 0001872195
Dear Thomas W. Farley:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a 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 letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our June 27, 2025 letter.

Amendment No. 5 to Draft Registration Statement on Form F-1
Summary
Recent Developments, page 20

1. We note your intention to provide preliminary information in the form of
ranges for
 the three months ended June 30, 2025. When you update your submission
with this
 preliminary information, please also discuss any trends evident from
this information
 as well as the underlying causes for changes in amounts compared to the
actual
 amounts provided for the three months ended June 30, 2024.
 July 16, 2025
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the three months ended March 31, 2025 and 2024
Change in fair value of digital assets held, net, page 167

2. Please revise your disclosure to explain the $142 million impairment
losses of digital
 assets held - intangible assets. To the extent appropriate, link this
disclosure to your
 other comprehensive income/loss disclosure at the bottom of page 168.
 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at
202-551-3855
if you have questions regarding comments on the financial statements and
related
matters. Please contact David Gessert at 202-551-2326 or J. Nolan McWilliams at
202-551-
3217 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Erin E. Martin
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 27, 2025

Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005

 Re: Bullish
 Amendment No. 4 to Draft Registration Statement on Form F-1
 Submitted June 18, 2025
 CIK No. 0001872195
Dear Thomas W. Farley:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a 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 letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our June 4, 2025 letter.

Amendment No. 4 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Digital Assets held - intangible assets, inventories and financial assets, page
166

1. We acknowledge your response to prior comment 3. As a supplement to risk
factor
 and other MD&A disclosure, please revise footnote (ii) to the table on
page 166 that
 provides either the exact amounts of wrapped bitcoin and wrapped ether
included in
 the table or a statement that provides a sense of the magnitude of
wrapped tokens.
 June 27, 2025
Page 2

Notes to the Consolidated Financial Statements
Note 12. Taxation
(b) Reconciliation between tax expense and accounting loss at applicable tax
rates, page F-46

2. We acknowledge your response to prior comment 6. Please address the
following:
 Tell us the amount of your compensation accrual and the related tax
impact at
 both December 31, 2023 and 2024.
 Tell us how the accrual for bonuses results in a tax expense in 2024
when bonus
 accruals typically are viewed as deductible temporary differences and
are not
 expected to impact the rate reconciliation required by IAS 12.81(c).
 As you characterize the reconciling item as related to unrecognized
temporary
 differences, clarify whether you did not take a tax deduction for book
purposes for
 bonuses earned and accrued in 2024. If so, tell us why not and
reference for us the
 authoritative literature you rely upon to support your accounting.

 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at
202-551-3855
if you have questions regarding comments on the financial statements and
related
matters. Please contact David Gessert at 202-551-2326 or J. Nolan McWilliams at
202-551-
3217 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Erin E. Martin
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 June 4, 2025

Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005

 Re: Bullish
 Amendment No. 3 to
 Draft Registration Statement on Form F-1
 Submitted May 21, 2025
 CIK No. 0001872195
Dear Thomas W. Farley:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a 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 letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 14, 2025 letter.

Amendment No. 3 to Draft Registration Statement on Form F-1
Summary Consolidated Financial and Other Data, page 22

1. We note that you present net income/(loss) attributable to owners and
non-controlling
 interests on the top of page 23, but the amounts presented for 2024 are
those related to
 total comprehensive income. Please revise your presentation to present
the appropriate
 net income amount.
 June 4, 2025
Page 2
Capitalization, page 116

2. Please revise your presentation to include your debt in total
capitalization. See Item
 3B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Digital Assets held - intangible assets, inventories and financial assets, page
165

3. In footnote (ii) to the tables on pages 165 and 166 you indicate that
the BTC and ETH
 quantities presented include wrapped tokens such as wBTC and weETH. In
Note 2.8
 on page F-22 you indicate that you derecognize digital assets
transferred to smart
 contracts and recognize the protocol-specific digital assets received in
return. In your
 response, please tell us the amounts of these wrapped token along with
your
 consideration for separately disclosing the quantities and specific
wrapped tokens
 included in your tables given that wrapped tokens present additional
risks to the
 tokens underlying them.
Certain Relationships and Related Party Transactions
Loan Agreement with SPV KY Limited, page 189

4. Please clarify why the reference to "block.one" is deleted from the
first sentence of
 this section.
Consolidated Statements of Cash Flows, page F-8

5. We note approximately $5.6 billion each of non-cash purchases of and
non-cash
 proceeds from disposals of digital assets held - intangible assets as
disclosed at the
 bottom of page F-9. Please tell us the nature of these transactions and
quantify for us
 the significant types of transaction underlying these amounts.
Notes to the Consolidated Financial Statements
Note 12. Taxation
(b) Reconciliation between tax expense and accounting loss at applicable tax
rates, page F-46

6. We note that the $4.2 million "Others" reconciling item in the table for
2024
 represents about 84% of your recorded $5.0 million income tax expense.
Please tell us
 the nature of the tax attributes underlying your "Others" reconciling
item and tell us
 your consideration for separately identifying and disclosing any
material individual
 amounts.
Note 29. Financial risk management
(c) Digital asset risk
(i) Risks with respect to customers' digital assets, page F-67

7. In the first paragraph on page F-68 you reference Note 13(c) which does
not appear to
 exist. Please tell us whether you have customer segregated inventory at
either
 December 31, 2024 or 2023. Otherwise, tell us where you have disclosed
these
 amounts.
 June 4, 2025
Page 3

 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at
202-551-3855
if you have questions regarding comments on the financial statements and
related matters.
Please contact David Gessert at 202-551-2326 or J. Nolan McWilliams at
202-551-3217 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Erin E. Martin
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 March 14, 2025

Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005

 Re: Bullish
 Amendment No. 2 to
 Draft Registration Statement on Form F-1
 Submitted February 28, 2025
 CIK No. 0001872195
Dear Thomas W. Farley:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a 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 letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our February 13, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1
Risk Factors
Our ownership and operation of Coindesk, page 28

1. Refer to your response to prior comment 9. Please disclose here the
substance of your
 response.
 March 14, 2025
Page 2
Certain Relationships and Related Party Transactions
Loan Agreement with SPV KY Limited, page 183

2. Refer to your response to prior comment 21. Please disclose the SPV KY
Limited
 interest rate.
Notes to the Consolidated Financial Statements
Note 2: Summary of principal accounting policies
2.4 Revenue recognition
Perpetual contracts transaction, page F-18

3. We note your response to prior comment 26. Please address the following
additional
 comments:
 We note from disclosure in Note 26 on page F-51 that you have a
digital currency
 perpetual contract derivative financial asset carrying amount of zero
with a
 notional amount of $9.9 million. We note no disclosure of digital
currency
 perpetual contract derivative financial liabilities. Please address
the following:
 o Tell us whether you offset the asset and liability positions in
accordance with
 IAS 32.42. If so, provide the disclosures required by IFRS 7.13B
through
 IFRS 7.13E, or tell us where you provided these disclosures or
why they are
 not warranted.
 o Tell us whether the carrying amount of your digital currency
perpetual
 contract derivative financial asset is zero because the contracts
have an
 hourly reset mechanism, as indicated in your response, and
therefore are
 settled and have no or minimal value at the end of the day. If
so, revise your
 disclosure to provide the digital currency perpetual contract
derivative
 financial liability carrying and notional amounts or tell us why
this disclosure
 is not warranted.
 Revise your disclosure, consistent with your response, to indicate
that you act a
 'clearing broker' in these transactions and highlight your
obligation to perform if a
 party with an offsetting position fails to perform.
2.8 Digital assets held - loan receivable, page F-19

4. We note your response to prior comment 27. In your revised disclosure
you indicate
 that "generally" loans and interest/lending fees must be repaid in the
same digital asset
 or fiat currency lent. Please tell us:
 the situations when a borrower can repay a loan and/or interest in
an asset other
 than the type of asset originally lent;
 the type of alternative assets a borrower may use to settle their
obligations;
 the frequency with which alternative assets were used by borrowers
to settle their
 obligations in each period presented in your submission; and
 the dollar amount of alternative assets used to settle obligations
in each period
 presented in your submission.
 March 14, 2025
Page 3
2.27 Borrowings from shareholders and Digital Assets Loan Payable, page F-32

5. We note your response to prior comment 35. Please address the following:
 Revise your disclosure regarding digital assets loans payable to
clarify:
 o whether you are restricted in your ability to use the borrowed
digital assets;
 and
 o whether your obligations to repay the amount borrowed and pay
interest
 charges are payable in the same digital asset borrowed.
 Revise your disclosure regarding recording digital assets borrowed
at "cost" to
 clarify how you measure such cost if no cash has been exchanged.
 Tell us whether you are required to post collateral for digital
assets borrowed. If
 so, revise your disclosure to provide your policy for the accounting
for collateral
 posted and separately reference for us the authoritative literature
you rely upon to
 support your accounting.
(b) Digital assets held - Loan Receivables, page F-41

6. We note your response to prior comment 32. Please address the following:
 Revise your disclosure to highlight that net lending/repayment
activity in the
 rollforward does not agree with the digital assets held - inventories
rollforward in
 Note 13(a) because it includes activity associated with loans of
digital financial
 assets.
 As the net repayment activity (including interest) in this
rollforward of $119.4 in
 2023 is less than the repayment activity depicted in the rollforward
in Note 13(a),
 please confirm that the difference is the result of net USDC loans
advanced and
 not net repayments as indicated in your response. Otherwise, tell us
why
 incremental repayments associated USDC loans over digital intangible
asset loans
 would result in fewer loan repayments.
Note 13: Digital assets held
(a) Digital assets held - Inventories, page F-41

7. We note your response to prior comment 31. Please revise your disclosure
to clarify
 that your disposal amounts depicted in the rollforward represent the
digital assets sales
 amounts and that these amounts do not agree with the amounts depicted in
your
 statements of profit or loss and other comprehensive income because the
amounts in
 the rollforward exclude digital financial asset sales.
Note 23: Borrowings from shareholders, page F-49

8. We note your response to prior comment 34. Please address the following:
 Revise your disclosure to clarify that you pay interest quarterly in
arrears on the
 last business day each quarter.
 Tell us why the price of bitcoin and its volatility are not
identified as significant
 inputs in valuing your liability for borrowings from shareholders in
Note 27(f).
 See guidance in IFRS 13.93(d) for requirements to disclose the
valuation
 techniques and inputs for Level 2 and Level 3 fair value measurements.
 March 14, 2025
Page 4

 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at
202-551-3855
if you have questions regarding comments on the financial statements and
related
matters. Please contact David Gessert at 202-551-2326 or J. Nolan McWilliams at
202-551-
3217 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Crypto Assets
cc: Erin E. Martin
</TEXT>
</DOCUMENT>

February 13, 2025
Thomas W. Farley
Chief Executive Officer
Bullish
10A Building A, 60 Nexus Way
Camana Bay, George Town
Grand Cayman, Cayman Islands, KY1-9005
Re:Bullish
Draft Registration Statement on Form F-1
Submitted January 17, 2025
CIK No. 0001872195
Dear Thomas W. Farley:
            We have reviewed your draft registration statement and have the following comments.
            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 a 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 letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Submitted January 17, 2025
General
1.We note your statements throughout regarding the applicability of PRC law to your
Hong Kong Subsidiaries and the discussion under Enforceability of Civil Liability in
Hong Kong. Please disclose how you concluded that the laws and regulations of the
PRC do not apply and disclose the basis of the discussion on page 209. To the extent
you have relied on an opinion of local counsel in either regard, disclose this, name
counsel, and have counsel file its consent to be named. To the extent you have not
relied on an opinion of local counsel in either regard, disclose this and revise the risk
factors as appropriate.

February 13, 2025
Page 2
Cover Page
2.In your Explanatory Note you disclose that you omit financial statements as of and for
the year ended December 31, 2021 and as of and for the the six months ended June
30, 2024 and 2023 because you reasonably believe that they will not be required to be
included in your Form F-1 at the time of your contemplated offering. In your next
submission, please revise your disclosure and assessment about your reasonable
expectations based on when you intend to publicly file your registration statement. In
this regard, we note that the audited financial statements in your submission are older
than 12 months and you do not provide the exhibit stipulated in Instruction 2 to Item
8.A.4 of Form 20-F. Refer to Compliance and Disclosure Interpretations Question
101.05 on Securities Act Forms for guidance on financial information that may be
omitted from draft registration statements for registrants that are not Emerging
Growth Companies.
Frequently Used Terms, page 1
3.Please revise your definition of "China or the PRC" to include Hong Kong and Macau
and clarify that the "legal and operational" risks associated with operating in China
also apply to your operations in Hong Kong. You may clarify that "China or the PRC"
does not include Hong Kong or Macau when you are referencing specific laws and
regulations adopted by the PRC.
Summary
Our Service Offerings, page 10
4.Please summarize how you earn revenues from each of the offerings discussed.
5.Please reconcile your disclosure on pages 10 and 118 that you "executed over $330
million in total futures trading volume in 2024" with your disclosure on pages 15 and
123 that your perpetual futures trading business "has grown to an average daily
volume of more than $330 million since launch in December 2023."
Summary of Risk Factors, page 17
6.Please summarize in the second to last bullet point the risks of doing business in Hong
Kong described on pages 98-104.
Risk Factors, page 24
7.Please add a risk factor describing the risks of speculation in the digital asset markets,
including the risk that the perception of a more favorable regulatory environment may
result in increased speculative activity. We note your disclosure on page 11 regarding
the substantial rise in ADV in the fourth quarter of 2024.
Our ownership and operation of CoinDesk, page 27
8.Refer to the fourth paragraph. Please disclose whether you have created information
barriers or other policies or procedures to ensure compliance with securities laws
relating to material non-public information.

February 13, 2025
Page 3
9.Refer to the last paragraph. Please describe the policies and procedures to limit and
mitigate conflicts of interest. To the extent a policy or procedure is not yet in effect,
disclose the time frame for implementation.
Fluctuations in interest rates could negatively impact us, page 32
10.To the extent material, please quantify the amount of outstanding indebtedness subject
to variable interest rates.
We face significant customer concentration risk, page 33
11.Please place these risks in context by quantifying the number of customers and
percentage of trading volume or revenue, as applicable, attributable to the significant
customers discussed.
We are exposed to risks relating to the availability of capital, page 34
12.Refer to the second paragraph. To the extent material, please quantify the minimum
capital requirements by jurisdiction.
The redemption risk and regulatory risk associated with stablecoins, page 60
13.Please place redemption risk in context by describing depegging events involving
USDC and USDT and the underlying reserve policies for each of USDC, USDT, and
PYUSD.
Our failure to obtain required regulatory licenses or approvals, page 68
14.Refer to the third paragraph. Please describe the policies and procedures you have
implemented to limit the availability of your products and services in the U.S. and
other jurisdictions where you have not received licenses or approvals. Also discuss the
risk that these policies and procedures may not be effective.
Business
Overview, page 116
15.Refer to the first bullet point. Please disclose the total global spot trading volume in
dollars for the peer set of exchanges in 2024 and, if available, the total global spot
trading volume across all exchanges. Similarly revise the summary disclosure on page
8.
Growth Strategy, page 123
16.Please briefly describe your expansion plans in the U.S., including the potential scope
of operations, regulatory capital requirements, and anticipated time frame to enter the
U.S. market.
Bullish Exchange
Trading Technology and Services, page 126
17.Please substantiate that Bullish Exchange’s largest BTC and ETH markets feature
lower total slippage and better consistency of order book depth.
18.Refer to the carryover bullet point on pages 126-27. Please clarify for which spot
markets AMMI orders and third-party market makers provide liquidity.

February 13, 2025
Page 4
Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Highlights, page 142
19.Please revise your first bullet to disclose your IFRS net loss of $4,246 million in 2022.
Liquidity and Capital Resources
Cash Flows
Cash Flows (Used in) / Provided by Operating Activities, page 159
20.Please tell us whether the repayments of loans that resulted in increased digital asset
inventories and financial assets in 2023 are cash or non-cash transactions. If non-cash,
revise your disclosure to discuss the cash drivers of your operating activities.
Certain Relationships and Related Party Transactions
Loan Agreement with SPV KY Limited, page 181
21.Regarding the loan with SPV KY Limited, please disclose the aggregate amount, the
largest amount outstanding during the period covered, the amount outstanding as of
the latest practicable date, and the interest rate. Similarly revise the first full risk factor
on page 29. Additionally, file the amended agreement as an exhibit.
Underwriting, page 194
22.Please quantify here and on page 20 the number of shares subject to lock-up
agreements. Also revise the first full paragraph on page 196 to briefly describe the
factors the underwriters may consider in determining to release securities subject to
the lock-up agreements.
Consolidated Statements of Cash Flows, page F-8
23.We note your inclusion of the (increase)/decrease in digital assets held - financial
assets in the operating activities section of your cash flow statements. Please tell us
more about your basis for this presentation that references the authoritative accounting
literature you relied upon including your consideration for classification within
investing activities.
24.We note your inclusion of the decrease/(increase) in digital assets held - loan
receivable in the operating activities section of your cash flow statements. Please tell
us more about your basis for this this presentation that references the authoritative
accounting literature you relied upon.
Notes to the Consolidated Financial Statements
Note 2: Summary of principal accounting policies
2.4 Revenue recognition
AMMI Trades - Purchase of digital assets by the AMMI from customers, page F-17
You disclose that remeasurement of the transaction price of purchases by the AMMI
from customers is included within the "Change of fair value of digital assets and other
revenue" under the "Change in fair value of digital assets held, net" in the
consolidated statement of profit and loss. As the components of the "Change in fair
value of digital assets held, net" disclosed in Note 8 on page F-38 does not include a
"Change of fair value of digital assets and other revenue" line item, please revise your 25.

February 13, 2025
Page 5
disclosure in these notes to clarify where this change in fair value is reflected in your
financial statements and related notes.
Perpetual contracts transaction, page F-18
26.You disclose that you provide a service to match or fulfill customers' orders to trade
perpetuals. You also disclose that these contracts are regarded as principal
transactions and, in Note 2.12 that these contracts are derivatives. Please provide us
an analysis supporting your accounting and presentation for these contracts and,
where appropriate, reference for us the authoritative literature you rely upon to
support your accounting. In your response:
•Specifically tell us why you present this activity net on the face of your statements
of profit or loss and other comprehensive income as you indicate that these are
principal transactions.
•Tell us whether you are a party to the perpetual contracts you trade. In other
words, tell us whether you write the derivatives or whether they are exchange
traded or over-the-counter contracts that you purchase from others to then resell.
2.8 Digital assets held - loan receivable, page F-19
27.Please revise to disclose the general terms of your fiat and digital asset loans. With
regard to your digital asset loans, please disclose:
•Whether any restrictions exist on the borrower's ability to use the lent digital
assets;
•Whether your loans have fixed or open-ended maturities;
•Whether the interest/lending fee component is fixed or variable;
•Whether you have a call option or the borrower has a put option;
•The frequency of interest/lending fee payments; and
•Whether the loan and interest/lending fees must be paid in the same digital asset
lent or whether it can be settled in some other digital asset or fiat.
28.We note that you loan both fiat and digital assets and that in Note 7 on page F-37 you
record "Income from digital assets lending" as an other revenue. Please revise your
disclosure to clarify where you record fiat loans receivable on your balance sheets and
interest income on these loans in your statements of profit or loss and other
comprehensive income. Separately tell us the amount of your fiat loans for each
balance sheet presented in your filing and the amounts of interest income recorded
during each period presented in your filing.
2.22 Current and deferred taxation, page F-28
29.In the first full paragraph on page F-29 you disclose that you recognize a provision for
uncertain matters considered probable that there will be a further outflow of funds to a
tax authority. Please tell us how your policy complies with the provisions of IFRIC
23.9 through 23.12 and, if so, revise your policy note to reframe the disclosure
regarding the probable acceptance of the tax treatment by the taxation authority and, if
so, how you measure the amount of the provision or benefit.

February 13, 2025
Page 6
Note 5: Digital assets sales, page F-35
30.We note your disclosure of revenues by each major customer on page F-36. Please
confirm to us that Customer 1 and Customer 2 in the table for 2022 are the same as
Customer 1 and Customer 2, respectively, in the table for 2023. If not, revise your
disclosure to identify which, if any, of the customers are the same across periods as
important information might be gleaned from volume changes over the years for
individual major customers.
Note 13. Digital assets held
(a) Digital assets held - Inventories, page F-41
31.Please tell us why the amounts identified as disposals in this rollfoward of $72,763
million in 2022 and $115,529 million in 2023 do not agree with amounts depicted in
Note 6 for the cost of digital assets derecognized; either the total costs or the costs
identified as "On the Exchange." Provide us a detailed reconciliation of these
amounts.
32.Please tell us why the net repayment of digital asset loan receivables depicted in the
rollforward for 2023 of $132.5 million does not agree with the net amounts presented
in the rollforward in Note 13(b) for digital asset loan receivables repaid, net of $122.2
million less the $2.8 million of interest. Provide us a detailed reconciliation of these
amounts.
(b) Digital assets held - Loan Receivables, page F-41
33.Please revise your disclosure to provide quantitative information about the gross
carrying amount of your loans by credit risk rating grades as stipulated in IFRS
7.35M, IFRS 7.B8I and IFRS 7.B8J. Otherwise, please tell us why this disclosure is
not warranted.
Note 23: Borrowings from shareholders, page F-50
Please provide us an analysis of your accounting for your loan facility with Block.one
upon initial draw, at amendment on December 12, 2023 and going forward. Reference
for us the specific authoritative literature you rely upon to support your accounting. In
your response, at a minimum, please address the following:
•Provide us a summary of the significant terms, specifically explaining the
mechanics for draw-downs and repayments in the various U.S. dollar, bitcoin and
USDC components.
•Clarify whether the $396.7 million attributed to the 9,600 bitcoin borrowed is the
fair value on the date of borrowing, the December 31, 2023 balance sheet date, or
some other date.
•As you indicate that the loan is denominated in U.S. dollars, tell us the impact of
price changes on the 9,600 bitcoin borrowed.
•Specifically identify for us the features of the borrowing that you identify as
embedded derivatives.
Explain why these embedded derivatives are not separated from the host
borrowing and why the entire instrument is measured at fair value through profit •34.

February 13, 2025
Page 7
and loss.
•Explain how the $74 million equity contribution at issuance was determined and
why it is recorded in equity.
•Explain why there apparently is no profit or loss impact of the borrowing in 2023.
In this regard, it appears from Note 27(f) that there was no change in fair value of
the borrowings from issuance through December 31, 2023.
Note 24: Digital assets loan payable, page F-51
35.Please revise your filing to provide a policy note that discloses how you account for
borrowings denominated in digital assets.
Note 27: Financial risk management
(a) Credit risk, page F-52
36.On page F-53 you disclose that your loans receivables (both fiat and digital asset
loans) are collateralized by fiat and digital assets in the borrowers' spot account, that
you monitor collateral values daily and that potential credit risk exposure is further
mitigated by the guarantees obtained from the borrower or the borrower's parent
company. On page F-54 you disclose that the allowance for expected credit losses was
inconsequential during 2023 and