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CORRESP
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 BIT Mining Limited

 428 South Seiberling Street

 Akron, Ohio 44306

 United States of America

 May 28, 2025

 VIA EDGAR

 Division of Corporation Finance
Office of Technology
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 Attention: Ms. Lulu Cheng

 Re: BIT Mining Limited
Registration Statement on Form F-3 (File No. 333- 287337)

 Dear Ms. Cheng:

 Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the "Securities Act"), BIT Mining Limited (the "Company") hereby requests that the effectiveness
of the above-referenced Registration Statement on Form F-3 (the "Registration Statement") of the Company be accelerated
by the Securities and Exchange Commission (the "Commission") to, and that the Registration Statement become effective at 4:00
P.M., Eastern Time, on May 30, 2025, or as soon thereafter as practicable.

 If there is any change in the acceleration request
set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration
of the effectiveness of the Registration Statement in accordance with Rule 461 under the Securities Act. Such request may be made
by an executive officer of the Company or by any attorney from the Company's U.S. counsel, Simpson Thacher & Bartlett LLP.

 Very truly yours,

 BIT Mining Limited

 By:
 /s/ Bo Yu

 Name:
 Bo Yu

 Title:
 Chairman of the Board and Chief Operating Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 23, 2025

Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
428 South Seiberling Street
Akron, Ohio 44306

 Re: BIT Mining Limited
 Registration Statement on Form F-3
 Filed May 16, 2025
 File No. 333-287337
Dear Xianfeng Yang:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Lulu Cheng at 202-551-3811 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Yi Gao
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
February 2, 2024
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Years Ended December 31, 2021 and 2022
File No. 001-36206
Dear Xianfeng Yang:
            We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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    Simpson Thacher & Bartlett

    icbc
    tower, 35th floor

    3
    garden road, central

    hong
    kong

    telephone:
    +852-2514-7600

    facsimile:
    +852-2869-7694

    Direct Dial Number

    +852-2514-7620

    E-mail Address

    ygao@stblaw.com

August 31, 2023

CONFIDENTIAL AND VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Ms. Kathleen Collins

    Ms. Megan Akst

    Re:
    BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2022

Filed April 17, 2023

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated August 17, 2023 (the “August 17 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2022 filed with the Commission on April 17, 2023 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the August 17 Comment Letter. The Staff’s comments are retyped below in bold italic font for
your ease of reference. The Company respectfully advises the Staff that where the Company proposes to add or revise disclosure in its
future annual reports on Form 20-F in response to the Staff’s comments, the changes to be made will be subject to relevant
factual updates and changes in relevant laws or regulations, or in interpretations thereof.

Simpson Thacher & Bartlett

August 31, 2023 -2- Division of Corporation Finance

U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December 31, 2022

Item 5. Operating and Financial Review Prospects Results of Operations

The year ended December 31, 2022 compared with the year ended December 31, 2021, page 65

    1.
    We note your proposed revised disclosures in response to prior comment 4. Please revise to separately discuss and quantify the revenue and cost of revenue from each of the primary and sub mining pool services so to better clarify the potential significant disparity in gross profit for each.

In response to the Staff’s comment, in the Company’s
future filings, the Company will revise to separately discuss and quantify the revenue and cost of revenue from each of the primary and
sub mining pool services and to discuss the reasons for the gross profit or gross loss for each. The proposed revised disclosures are
set forth in Annex A.

Sub Mining Pool Services, page F-26

    2.
    Please address further the following as it relates to your response to prior comment 6.

    ·
    Describe, in detail, how the technology and process work such that you both transfer computing power generated by your mine pool participants to the mining pools in which you participate and control the computing power of your mining pool participants before you transfer it to the mining pool operators of the mining pools in which you participate. For example, are you relaying the block header, the block version, and the block data provided by the mine pool operator of the mine pool in which you participate as well as your wallet address to the participants in your mining pool?

    ·
    Specify the terms of your Agreements that provide the company with control over the service of providing computing power before it is provided to the third-party pool operators and the ability to transfer such service.

    ·
    Highlight any significant differences between the rights and obligations of your mine pool participants and your rights and obligations in the mining pools in which you participate. As part of that comparison, compare the payout mechanism of the pool you operate with the pools with which you participate, identifying each significant variable effecting both the block reward and transaction fee components of those payouts.

    ·
    Explain to us how you receive payouts from the third-party pools in which you participate, including whether you provide your wallet address to the third-party operator. In this regard, clarify whether rewards are received in BTC.com's wallet and then distributed to your mining pool participants' wallets.

    ·
    Summarize the material terms of, and provide us with a copy of, the Specific Service Agreement that is referenced in the BTC.com User Agreement. Also, identify the mining pools in which you participate and provide us with a copy of the agreements that specify the rights and obligations of the parties to those agreements.

Simpson Thacher & Bartlett

August 31, 2023 -3- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    Provide a comprehensive accounting analysis of how you determined that you control the computing power of the mining pool participant before it is provided to third-party pool operators. Refer to ASC 606-10-25-25.

The Company respectfully advises the Staff the following:

    ·
    For sub mining pool services, the Company decided to contribute all the computing power it obtained from BTC.com pool participants for mining bitcoins to the third-party mining pool operators. For mining of other types of cryptocurrencies in the BTC.com mining pool, the Company still provides primary mining pool services.

With respect to the technology and processes of the sub
mining pool services, the entire user registration and miner configuration processes remained the same as the processes before the Company
entered into the sub mining pool services, nor did the mining IP addresses change. The Company continues to display real-time hash rate
and expected mining profits information on its pool participants’ account dashboard. Before and after the Company entered into the
sub mining pool services, the BTC.com pool participants would not be able to tell any differences in terms of their mining experiences.
Upon the BTC.com pool participants connecting their mining equipment by configuring the equipment with the mining IP addresses provided
by BTC.com, the computing power would flow through the Company’s nodes and then be redirected to the third-party mining pool operators’
servers. The Company’s nodes are provided by Cloudflare, a third-party network service provider, for enhanced network security and
reliability. During the mining process, the Company’s nodes would relay the necessary information for mining, such as the block
header, the block version, and the block data provided by the third-party mine pool operators, to the BTC.com pool participants. The block
rewards and transaction verification fees attached to each block placement would be deposited directly into the third-party mining pools’
wallets. As a result, the third-party mining pools’ wallet addresses were included in the block information used for mining.

In the processes described above, the Company controls the
computing power of the BTC.com pool participants before it is transferred to the third-party mining pool operators because: 1) it is up
to the Company to decide the specific portion of computing power to be transferred to the third-party mining pool operators, without any
consent required from BTC.com pool participants; 2) the information flows through its nodes and the Company is responsible for transferring
accurate and timely block information to both the pool participants and the third-party mining pool operators.

Simpson Thacher & Bartlett

August 31, 2023 -4- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    As the BTC.com mining pool operator, the Company and its pool participants entered into arrangements governed by the standard agreements on the website of BTC.com (BTC.com Pool Service Agreement1 and BTC.com User Agreement2). The aforementioned agreements are attached hereto as Annex C. In addition, there are some statements and FAQs made by BTC.com on its website and other customary business practices that together form the contract between BTC.com and its pool participants. The Company believes the following terms in the contract would provide the Company with control over the computing power before it is provided to the third-party pool operators and the ability to transfer such computing power:

    1)
    Section 6.1 of the BTC.com User Agreement specifies that “you agree that we reserve the right to limit, change, suspend or even terminate all or part of the Services at any time”.

    2)
    Section 8.2 of the BTC.com User Agreement specifies that “this agreement is binding upon you and BTC.com, and it did not create any third-party beneficiary rights. You may not assign or transfer any of your rights or obligations under the Agreement without prior written consent from BTC.com. BTC.com may assign or transfer any or all of its rights and obligations under the Agreement, in whole or in part, without notice or obtaining your consent or approval”.

Based on the terms above, BTC.com has the right to direct
the use of the computing power and is able to transfer such computing power to other parties without notice or obtaining its pool participants’
consent or approval.

    ·
    The Company respectfully advises the Staff that there are no significant differences between the rights and obligations of the Company’s mining pool participants in the Company's BTC.com mining pool and the Company’s rights and obligations in the third-party mining pools in which the Company participates except for the pool operators’ fee rate charged by the pool operators, which will be explained in further details below. However, since the arrangements between the Company and the Company’s mining pool participants, and the arrangements between the Company and the third-party mining pool operators were entered into and executed separately, the rights and obligations of the aforementioned arrangements were not related and would not impact each other. In the case that the Company did not receive the payments from the third-party mining pools, it would still be obligated to calculate, allocate and distribute the earnings or mining rewards to the BTC.com mining pool participants based on predetermined sharing mechanism.

1Annex
C page C-2 to C-4. It can also be found at https://activity.btc.com/agreement/#/miningservice?lang=en.

2Annex
C page C-5 to C-9. It can also be found at https://activity.btc.com/agreement/#/user?lang=en.

Simpson Thacher & Bartlett

August 31, 2023 -5- Division of Corporation Finance

U.S. Securities and Exchange Commission

The payout mechanism in the Company’s mining pool
and that in the third-party mining pools are both FPPS (Full Pay-Per-Share). The only variable between the payout mechanism of the BTC.com
mining pool and that of the third-party mining pools is the rate of pool operator fee retained by the pool operators. For ease of reference,
the Company included the formula of FPPS in the table below.

    Sharing mechanism
    Reward for pool participant

    FPPS
    Expected block rewards1*(1+FPPS rate2)*Computation submitted by the participant /Whole blockchain workload*(1-Pool operator fee rate set up by mining pool)

1. Expected block rewards: expected new block rewards granted
by the blockchain network, taken the bitcoin network as an example, 6.25 bitcoins in every 10 minutes approximately in the current halving
cycle.

2. FPPS rate: prior day transaction fee earned within the pool
divided by prior day block rewards earned within the pool.

Under the FPPS payout mechanism, the expected block
rewards and transaction verification fees were paid out as a whole from the third-party mining pools to the Company, and from the
Company to the Company’s mining pool participants, respectively. The Company also receives from the third-party mining pools
and pays to its pool participants, elastos (“ELA”) and namecoins (“NMC”) as the bonus from mining bitcoins. The value of the two
bonus coins is immaterial. The Company respectfully advises the Staff that the pool operator fee rate set up by BTC.com for bitcoin
was 4%3. The pool operator fee rates set up by the
third-party mining pool operators in which the Company participates were lower due to discounts offered to larger pool
participants.

    ·
    The Company respectfully advises the Staff that the Company provides its wallet address to each of the two third-party mining pools in which the Company participates. On a daily basis, the third-party mining pools would distribute, and the Company would receive the mining rewards determined based on the aforementioned FPPS payout mechanism for providing computing power during the period from UTC 00:00 to UTC 23:59 of the previous day. The Company respectfully advises the Staff that the Company would usually receive the rewards statement from the third-party mining pools within one hour after UTC 0:00 every day and the third-party mining pools would initiate the payout soon after the rewards statement is made available. Depending on the time it takes the blockchain to confirm the transactions, the payouts from the third-party mining pools are usually received before UTC 8:00 every day. Once the rewards statements are received, the Company analyzes the data and calculates the corresponding mining rewards it should distribute to each pool participant based on the FPPS payout mechanism. The Company would usually distribute mining rewards to the Company’s mining pool participants between UTC 02:00 and UTC 06:00. The third-party mining pools do not calculate the mining rewards of each of the BTC.com pool participants, nor do they distribute the mining rewards directly to the BTC.com pool participants. In the situation where the Company receives mining rewards from the third-party mining pools prior to making mining rewards distribution to its mining pool participants, the rewards were received in BTC.com’s wallets first, then were distributed to the wallets of the Company’s mining pool participants. It happens that the Company might receive the mining rewards from the third-party mining pools later than it distributes the mining rewards to the pool participants. In this case, the Company would use its own bitcoin reserves in the wallets to make mining rewards distributions to its mining pool participants.

3 https://help.pool.btc.com/hc/en-us/articles/900001116943-The-fee-settlement-mode-and-payment-threshold-in-BTC-com-pool

Simpson Thacher & Bartlett

August 31, 2023 -6- Division of Corporation Finance

U.S. Securities and Exchange Commission

    ·
    The Company respectfully advises the Staff that the Specific Service Agreement referenced in the BTC.com User Agreement is the BTC.com Pool Service Agreement mentioned in the response to the second bullet point of comment 2. Please refer to below for a summary of material rights and obligations of each party in the aforementioned arrangement:

Mining pool participant (BTC.com pool participants):

    i.
    The pool participants are responsible for reviewing the latest version of the agreement in a timely manner. If the pool participants do not agree to the latest version of the agreement after any modification, they shall suspend registration for, or stop using the services provided by BTC.com.4

Mining pool operators (the Company):

    i.
    Have the right to make a unilateral determination to continue or terminate providing services to the users without their consent or prior notice.5

    ii.
    Reserves the right to switch the hashrate power to other currencies if problems of the mining currency itself may affect the mining output.6

4 BTC.com
Pool Service Agreement – 2nd paragraph

5 BTC.com
Pool Service Agreement Clause 2.2

6 BTC.com
Pool Service Agreement Clause 2.5

Simpson Thacher & Bartlett

August 31, 2023 -7- Division of Corporation Finance

U.S. Securities and Exchange Commission

The C

United States securities and exchange commission logo
August 17, 2023
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 17, 2023
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your July 25, 2023 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
July 11, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 5. Operating and Financial Review Prospects Results of Operations
The year ended December 31, 2022 compared with the year ended December 31, 2021, page 65
1.We note your proposed revised disclosures in response to prior comment 4.  Please revise
to separately discuss and quantify the revenue and cost of revenue from each of the
primary and sub mining pool services so to better clarify the potential significant disparity
in gross profit for each.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 17, 2023 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
August 17, 2023
Page 2
Sub Mining Pool Services, page F-26
2.Please address further the following as it relates to your response to prior comment 6.
•Describe, in detail, how the technology and process work such that you both transfer
computing power generated by your mine pool participants to the mining pools in
which you participate and control the computing power of your mining pool
participants before you transfer it to the mining pool operators of the mining pools in
which you participate. For example, are you relaying the block header, the block
version, and the block data provided by the mine pool operator of the mine pool in
which you participate as well as your wallet address to the participants in your
mining pool?
•Specify the terms of your Agreements that provide the company with control over the
service of providing computing power before it is provided to the third-party pool
operators and the ability to transfer such service.
•Highlight any significant differences between the rights and obligations of your mine
pool participants and your rights and obligations in the mining pools in which you
participate.  As part of that comparison, compare the payout mechanism of the pool
you operate with the pools with which you participate, identifying each significant
variable effecting both the block reward and transaction fee components of those
payouts.
•Explain to us how you receive payouts from the third-party pools in which you
participate, including whether you provide your wallet address to the third-party
operator.  In this regard, clarify whether rewards are received in BTC.com's wallet
and then distributed to your mining pool participants' wallets.
•Summarize the material terms of, and provide us with a copy of, the Specific Service
Agreement that is referenced in the BTC.com User Agreement.  Also, identify the
mining pools in which you participate and provide us with a copy of the agreements
that specify the rights and obligations of the parties to those agreements.
•Provide a comprehensive accounting analysis of how you determined that you control
the computing power of the mining pool participant before it is provided to third-
party pool operators.  Refer to ASC 606-10-25-25.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yi Gao

CORRESP
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    Simpson Thacher & Bartlett

    icbc tower, 35th floor

    3 garden road, central

    hong kong

    _____________________

    telephone: +852-2514-7600

    facsimile: +852-2869-7694

    Direct Dial Number

    +852-2514-7620

    E-mail Address

    ygao@stblaw.com

July 25, 2023

    CONFIDENTIAL AND VIA EDGAR

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Attention:      Ms. Kathleen Collins

    Ms. Megan Akst

 Re: BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2022

Filed April 17, 2023

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated July 11, 2023 (the “July 11 Comment Letter”) relating to the Company’s annual report on Form 20-F for the
fiscal year ended December 31, 2022 filed with the Commission on April 17, 2023 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the July 11 Comment Letter. The Staff’s comments are retyped below in bold italic font for your
ease of reference. The Company respectfully advises the Staff that where the Company proposes to add or revise disclosure in its future
annual reports on Form 20-F in response to the Staff’s comments, the changes to be made will be subject to relevant factual updates
and changes in relevant laws or regulations, or in interpretations thereof.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    ADAM
    S. GOLDBERG
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    kathryn
    kING  sudol
    christopher
    k.s. wong

resident
partners

simpson
thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
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    Angeles
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    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson Thacher & Bartlett

    July 25, 2023
    -2-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December
31, 2022

Item 3. Key Information, page 5

 1. Please revise here to include the proposed disclosures provided in paragraph 1 of the response to comment 3 in your December
30, 2022 letter.

In response to the Staff’s comment, in the Company’s future
annual reports on Form 20-F, the Company will revise on or about page 5 of “Item 3. Key Information” to include an updated
version of the proposed disclosures provided in paragraph 1 of the response to comment 3 in its December 30, 2022 response letter, consistent
with the changes set forth in Annex A.

Cash Flows through our Organization, page 6

 2. Please revise to include the proposed disclosures provided in comment
2 of your December 30, 2022 response letter. In this regard, quantify and discuss any cash flows and transfers of other assets by type
that have occurred between the holding company and its subsidiaries, and the direction of transfer including their tax consequences, if
any, for each period presented.

In response to the Staff’s comment, in the Company’s future
annual reports on Form 20-F, the Company will revise on or about page 6 under “Cash Flows through our Organization” to include
an updated version of the proposed disclosures provided in comment 2 of its December 30, 2022 response letter, consistent with the changes
set forth in Annex A.

The Company has supplemented such proposed disclosures to quantify
and discuss any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries,
and the direction of transfer including their tax consequences for each period presented. The Company respectfully advises the Staff that
since the Company disposed of its VIE structure by the end of 2021, there is no such VIE-related data available for 2022.

Holding Company Structure, page 6

 3. Please revise to improve legibility by increasing the font size of the text in your organization chart here and on page 58.

In response to the Staff’s
comment, in the Company’s future annual reports on Form 20-F, the Company will revise to improve legibility by increasing the
font size of the text in its organization chart on or about page 6 under “Holding Company Structure” and on or about
page 58. The proposed revised chart is set forth in Annex A.

    Simpson Thacher & Bartlett

    July 25, 2023
    -3-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

Item 5. Operating and Financial Review
and Prospects Results of Operations The year ended December 31, 2021 compared with the year ended December 31, 2020, page
67

 4. Please revise to discuss the reasons for the negative profit margins in your mining pool segment as disclosed in Note 24 and
explain whether you anticipate this trend to continue in future periods. We refer to comment 11 in your September 6, 2022 response letter.

In response to the Staff’s comment, in the Company’s future
filings, the Company will revise to discuss the reasons for the negative profit margins in its mining pool segment as disclosed in Note
24 and explain whether it anticipates this trend to continue in future periods. The proposed disclosures on or about page 65 are set forth
below.

The year ended December 31, 2022
compared with the year ended December 31, 2021

Revenues

 For the year ended December 31, 2022, revenues were mainly
comprised of revenues after inter-segment elimination from the mining pool business of US$593.2 million, the cryptocurrency mining business
of US$46.8 million and the data center business of US$10.0 million. For the year ended December 31, 2021, revenues were mainly comprised
of revenues after inter-segment elimination from the mining pool business of US$1,275.1 million, the cryptocurrency mining business of
US$39.4 million, and the data center business of US$11.8 million.

Operating cost and expenses

 Cost
of revenue. For the year ended December 31, 2022, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$600.7 million, the cryptocurrency mining business of US$42.0 million and the data center
business of US$14.2 million. For the year ended December 31, 2021, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$1,283.9 million, the cryptocurrency mining business of US$23.8 million, and the data center
business of US$14.3 million.

    Simpson Thacher & Bartlett

    July 25, 2023
    -4-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The gross losses for the years ended December 31, 2022 and 2021 were
US$7.5 million and US$8.8 million for the mining pool business, and US$4.2 million and US$2.4 million for the data center business. The
gross profits for the years ended December 31, 2022 and 2021 were US$4.9 million and US$15.6 million for the cryptocurrency mining business.

Regarding the mining pool business, for the year ended December
31, 2022, US$492.2 million revenues included in the revenue from mining pool segment were recognized from primary mining pool services.
Such revenues include block rewards and transaction verification fees from successful block placements. The Company also generates revenues
from sub mining pool services, where the Company contributes a portion of the computing power it obtained from BTC.com pool participants
to the third-party mining pool operators. In exchange, the Company is entitled to considerations in the form of cryptocurrencies from
the third-party mining pool operators calculated based on a predetermined formula regardless of whether the third-party mining pool operators
successfully validate the blocks. For the year ended December 31, 2021, the entire revenues included in the revenue from mining pool segment
were recognized from primary mining pool services. Cost of mining pool services primarily consists of mining rewards allocated to each
pool participant in exchange for their computing power contributed to the mining pool.

For primary mining pool services, the Company receives from
the blockchain the actual block rewards and distributes to the Company’s mining pool participants based on expected block rewards.
In other words, under the sharing mechanisms adopted by the Company for its primary mining pool services, the mining pool participants
are entitled to the compensation regardless of whether the Company successfully records a block. Such variability when the actual block
rewards are different from the expected block rewards within the mining pool is referred as the lucky index. The negative profit margin
in the mining pool segment was mainly caused by fluctuation in the lucky index. During certain periods in 2021 and 2022, the primary mining
pool services had a lucky index below 100% and had to distribute more block rewards to the mining pool participants than the actual blocks
it received. The fluctuation in lucky index is largely a result of the randomness and uncertainty inherent in the primary mining pool
services. As such, for primary mining pool services, the Company is unable to predict whether this trend would continue in future periods.

In order to mitigate the impact of fluctuation in the lucky
index, during 2022, the Company entered into the sub mining pool services. As the Company is entitled to considerations from the third-party
mining pool operators regardless of whether the third-party mining pool operators successfully validate the blocks, the Company generated
positive gross margin from sub mining pool services during the year ended December 31, 2022. The Company expects to maintain its cooperation
with the third-party mining pool operators, as a result, the Company does not expect negative profit margins from its sub mining pool
services in future periods. However, the Company is unable to predict the trend for its overall mining pool segment.

With regards to the cryptocurrency mining business, the gross
profits are largely driven by the cryptocurrency prices.

For the data center business, revenues are generated from
providing its customers with rack space, utility, and cloud services such as virtual services, virtual storage, and data backup services.
Cost of revenue is primarily comprised of direct production cost related to data center service as well as depreciation and amortization
of the data centers. The gross losses of data center business for the year ended December 31, 2022 were mainly attributable to continuous
declines in cryptocurrency prices since the second quarter of 2022, which led its customers to suspend their cryptocurrency mining operations,
resulting in fewer revenues generated. The gross losses of data center business for the year ended December 31, 2021 were mainly due to
the closure and demolition of data centers in Sichuan, China in June 2021, and the depreciation and amortization costs related to the
construction of Ohio data center since October 2021 while the revenues generated from such date center during the year ended December
31, 2021 were limited. Due to the fluctuation in cryptocurrency prices, the Company is unable to predict whether the negative gross margin
of the data center business would continue in future periods.

    Simpson Thacher & Bartlett

    July 25, 2023
    -5-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The year ended December 31, 2021
compared with the year ended December 31, 2020

Operating cost and expenses

Cost
of revenue.  For the year ended December 31, 2021, cost of revenue was mainly comprised of cost of revenue after inter-segment
elimination from the mining pool business of US$1,283.9 million, the cryptocurrency mining business of US$23.8 million and the data center
business of US$14.3 million. The respective gross loss was US$8.8 million for the mining pool business, US$2.4 million for the data center
business, and gross profit of US$15.6 million for the cryptocurrency mining business. Please refer to above for discussion of the reasons
for the negative gross margin of the mining pool business and the data center business. There were no operations of the mining pool business,
the cryptocurrency mining business or the data center business in 2020.

Note 2. Summary of Significant Accounting Policies

Mining Pool Services, page F-25

 5. As noted in our prior comment 3, we continue to evaluate your conclusions related to contract inception and contract duration
as per your response to comment 3 in your March 1, 2023 letter.

The Company respectfully acknowledges the
Staff’s comment.

Sub Mining Pool Services, page F-26

 6. So that we may better understand your accounting policy for sub mining pool services, please address the following:

 · Explain further the nature of these sub mining pool arrangements with third-party pool operators.

 · Clarify how these arrangements "stabilize the mining rewards" that the Group is entitled to.

 · Provide us your analysis as to how you determined you are the principal such that revenue should be recognized gross in these
arrangements. Refer to ASC 606-10-55-36 to 55-40.

 · Clarify whether you are deemed the mining pool participant in the arrangement with the third party mining pool operator.

 · Describe in detail your rationale for classifying these revenues as mining pool revenues as opposed to cryptocurrency mining
revenues.

    Simpson Thacher & Bartlett

    July 25, 2023
    -6-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

The Company respectfully advises the Staff
the following:

 · The Company entered into arrangements with two third-party mining pool operators
and essentially became the mining pool participants of the third-party mining pools. Below is a summary of material rights and obligations
of these arrangements with the third-party pool operators:

Mining pool participant (the Company):

 i. Can shut down account at any time.

 ii. Right to monitor the mining status by receiving real-time mining hashrates, and mining earnings.

Mining pool operators (third-party mining pools):

 i. Provide billing statement to mining pool participants on a daily basis.

 ii. Determine and distribute mining rewards to mining pool participants using the FPPS (Full Pay-Per-Share) sharing mechanism. (Refer
to section below for further information on the FPPS sharing mechanism.)

 iii. Have the right to charge fees for mining pool services based on the specific fee rate published or otherwise agreed by both parties.

 iv. Have the right to make a unilateral determination to process or terminate providing services considering the results of unilateral
determination.

Based on the material rights and obligations summarized
above, the Company collects the computing power contributed by the Company’s individual mining pool participants in the BTC.com
mining pool and delivers such computing power to the third-party mining pool operators. In exchange, the Company is entitled to considerations
in the form of cryptocurrencies from the third-party mining pools calculated based on a predetermined formula regardless of whether the
third-party mining pool operators successfully validate the blocks. The Company receives the mining rewards distributed from the third-party
mining pool operators in the following day of providing the computing power and would also distribute the mining rewards to each of its
pool participant based on the predetermined formula on the same day. The rewards r

United States securities and exchange commission logo
July 11, 2023
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 17, 2023
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your April 12, 2023 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
March 22, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 3. Key Information, page 5
1.Please revise here to include the proposed disclosures provided in paragraph 1 of the
response to comment 3 in your December 30, 2022 letter.
Cash Flows through our Organization, page 6
2.Please revise to include the proposed disclosures provided in comment 2 of your
December 30, 2022 response letter.  In this regard, quantify and discuss any cash flows
and transfers of other assets by type that have occurred between the holding company and
its subsidiaries, and the direction of transfer including their tax consequences, if any, for
each period presented.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 July 11, 2023 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
July 11, 2023
Page 2
Holding Company Structure, page 6
3.Please revise to improve legibility by increasing the font size of the text in your
organization chart here and on page 58.
Item 5. Operating and Financial Review and Prospects
Results of Operations
The year ended December 31, 2021 compared with the year ended December 31, 2020, page 67
4.Please revise to discuss the reasons for the negative profit margins in your mining pool
segment as disclosed in Note 24 and explain whether you anticipate this trend to continue
in future periods. We refer to comment 11 in your September 6, 2022 response letter.
Note 2. Summary of Significant Accounting Policies
Mining Pool Services, page F-25
5.As noted in our prior comment 3, we continue to evaluate your conclusions related to
contract inception and contract duration as per your response to comment 3 in your March
1, 2023 letter.
Sub Mining Pool Services, page F-26
6.So that we may better understand your accounting policy for sub mining pool services,
please address the following:
•Explain further the nature of these sub mining pool arrangements with third-party
pool operators.
•Clarify how these arrangements "stabilize the mining rewards" that the Group is
entitled to.
•Provide us your analysis as to how you determined you are the principal such that
revenue should be recognized gross in these arrangements. Refer to ASC 606-10-55-
36 to 55-40.
•Clarify whether you are deemed the mining pool participant in the arrangement with
the third party mining pool operator.
•Describe in detail your rationale for classifying these revenues as mining pool
revenues as opposed to cryptocurrency mining revenues.
Note 24. Segment Reporting, page F-61
7.Please revise the geographic breakdown table to explain the reference to Blockchain as a
geographic location similar to the information provided in your response to comment 14
in your December 30, 2022 letter.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 July 11, 2023 Page 3
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
July 11, 2023
Page 3
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yi Gao

CORRESP
1
filename1.htm

    Simpson Thacher &
                    Bartlett

    icbc
                    tower, 35th floor

    3 garden
    road, central

    hong
kong

    telephone:
                    +852-2514-7600

    facsimile:
    +852-2869-7694

    Direct Dial Number

    +852-2514-7620

    E-mail
                                            Address

    ygao@stblaw.com

 April 12, 2023

CONFIDENTIAL AND VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Kathleen Collins

                                                                                Ms. Megan
Akst

 Re: BIT
                                            Mining Limited

                                            Form 20-F for the Fiscal Year Ended December 31, 2021

                                            Filed April 7, 2022

                                            File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated March 22, 2023 (the “March 22 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2021 filed with the Commission on April 7, 2022 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the March 22 Comment Letter. The Staff’s comments are retyped below in bold italic font for
your ease of reference.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    ADAM
    S. GOLDBERG
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    kathryn
    kING  sudol
    christopher
    k.s. wong

resident
partners

simpson
thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

Simpson Thacher & Bartlett

April 12, 2023 -2- Division of Corporation Finance

U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December 31, 2021

Cryptocurrency Assets, page F-18

 1. We
                                            note your response to prior comment 2 where you state that you use the price quoted each
                                            day at 0:00 UTC to determine the fair value used for impairment assessment. We do not believe
                                            your accounting policy complies with ASC 350-30-35-19, which states in part, “If the
                                            carrying amount of an intangible asset exceeds its fair value, an entity shall recognize
                                            an impairment loss in an amount equal to that excess.” As such, we believe your accounting
                                            policy represents an “error in previously issued financial statements” that should
                                            be corrected.

The
Company respectfully acknowledges the Staff’s comment and has evaluated the materiality of the error from qualitative
and quantitative perspectives in accordance with Staff Accounting Bulletin (“SAB”) 99, Materiality, and SAB
108, Considering the Effects of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial
Statements. Based on the evaluation, the error is not material to the previously issued financial statements. The Company
decided to correct the error prospectively by revising the previously issued financial statements and include disclosures in its
annual report on Form 20-F for the year ended December 31, 2022 as follows:

Revision of Previously Issued
Financial Statements

During the preparation of this Annual
Report, the Company identified and corrected an immaterial error related to the impairment calculation of cryptocurrency assets. The
Company has been historically calculating the impairment of cryptocurrency assets on a daily basis using a spot price at a standard cutoff
time. The Company determined such a method was not in compliance with ASC 350-30-35-19 which requires the recognition of impairment when
carrying value exceeds fair value. The Company further determined that the intraday lowest quoted price should be utilized in calculating
impairment of the Company’s cryptocurrency assets.

In
accordance with Staff Accounting Bulletin (“SAB”) 99, Materiality, and SAB 108, Considering the Effects
of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial Statements, the Company evaluated the materiality
of the error from qualitative and quantitative perspectives, and concluded that the error was immaterial to the Consolidated
Balance Sheet as of December 31, 2021 and Consolidated Statement of Comprehensive Loss, Changes in Shareholders’ Equity and
Cash Flows for the year ended December 31, 2021. The following tables present the impact of this error on the Company’s financial
statements as of December 31, 2021 and for the year ended December 31, 2021:

Simpson Thacher & Bartlett

April 12, 2023 -3- Division of Corporation Finance

U.S. Securities and Exchange Commission

    As of December 31, 2021

    Consolidated Balance Sheet

 Amounts in thousands U.S. dollars (“US$”)

    As Reported
    Effect of

Adjustment
    As Revised

    Cryptocurrency assets
    $ 55,077
    $ (1,887 )
    $ 53,190

    Total current assets
      95,143
      (1,887 )
      93,256

    Total assets
      296,116
      (1,887 )
      294,229

    Accumulated deficit and statutory reserve
      (384,867 )
      (1,887 )
      (386,754 )

    Total shareholders' equity
      207,150
      (1,887 )
      205,263

    Total liabilities and shareholders' equity
      296,116
      (1,887 )
      294,229

    For the year ended December 31, 2021

    Consolidated Statement of Comprehensive Loss

 Amounts in thousands of U.S. dollars (“US$”), except for number of shares and per share (or ADS) data

    As Reported
    Effect of

Adjustment
    As Revised

    Net gain on disposal of cryptocurrency assets
    $ 6,717
    $ 4,675
    $ 11,392

    Impairment of cryptocurrency assets
      (31,757 )
      (6,562 )
      (38,319 )

    Operating loss from continuing operations
      (68,350 )
      (1,887 )
      (70,237 )

    Loss before income tax from continuing operations
      (63,925 )
      (1,887 )
      (65,812 )

    Net loss from continuing operations
      (63,566 )
      (1,887 )
      (65,453 )

    Net loss
      (72,487 )
      (1,887 )
      (74,374 )

    Net loss attributable to BIT Mining Limited
      (60,516 )
      (1,887 )
      (62,403 )

    Losses per share for Class A and Class B ordinary shares outstanding-Basic and Diluted:

    Net loss from continuing operations
      (0.08 )
      (0.01 )
      (0.09 )

    Net loss
      (0.09 )
      (0.01 )
      (0.10 )

    Losses per American Depositary Share ("ADS*") (1 ADS represents 100 Class A ordinary shares)-Basic and Diluted:

    Net loss from continuing operations
      (8.32 )
      (0.30 )
      (8.62 )

    Net loss
      (9.72 )
      (0.30 )
      (10.02 )

* American Depositary Shares, which are traded
on the NYSE. Each ADS represents one hundred Class A ordinary shares of the Company.

Note: Losses per ADS have been retrospectively
adjusted for the ADS Ratio Change from the former ADS Ratio of 1 ADS to 10 Class A ordinary shares, to the current ADS Ratio of
1 ADS to 100 Class A ordinary shares, effective on December 23, 2022.

Simpson Thacher & Bartlett

April 12, 2023 -4- Division of Corporation Finance

U.S. Securities and Exchange Commission

    For the year ended December 31, 2021

    Consolidated Statement of Cash Flows

 Amounts in thousands U.S. dollars (“US$”)

    As Reported
    Effect of

Adjustment
    As Revised

    Net loss
    $ (72,487 )
    $ (1,887 )
    $ (74,374 )

    Impairment of cryptocurrency assets
      31,757
      6,562
      38,319

    Net gain on disposal of cryptocurrency assets
      (6,717 )
      (4,675 )
      (11,392 )

    For the year ended December 31, 2021

    Consolidated Statement of Changes in Shareholders' Equity

 Amounts in thousands U.S. dollars (“US$”)

    Accumulated
    deficit
 and statutory reserve
    Total shareholders'

 equity

    Net loss for the year (as reported)
    $ (60,516 )
    $ (72,487 )

    Net loss for the year (effect of adjustment)
      (1,887 )
      (1,887 )

    Net loss for the year (as revised)
      (62,403 )
      (74,374 )

    Balance as of December 31, 2021 (as reported)
      (384,867 )
      207,150

    Balance as of December 31, 2021 (effect of adjustment)
      (1,887 )
      (1,887 )

    Balance as of December 31, 2021 (as revised)
      (386,754 )
      205,263

The Company also proposes to revise
and include the following accounting policy on cryptocurrency assets in its future filings:

“Cryptocurrencies held are accounted
for as intangible assets with indefinite useful lives. An intangible asset with an indefinite useful life is not amortized but assessed
for impairment quarterly, or more frequently, when events or changes in circumstances occur, principally decreases in the quoted prices
of the cryptocurrencies, indicating that it is more likely than not that the indefinite-lived asset is impaired. In determining if an
impairment has occurred, the Company considers the intraday lowest quoted price of one unit of cryptocurrency asset since acquiring the
cryptocurrency asset. If the then current carrying value of the unit of cryptocurrency exceeds the fair value so determined, an impairment
loss has occurred with respect to those units of cryptocurrencies in the amount equal to the difference between their carrying values
and the fair value determined. To the extent an impairment loss is recognized, the loss establishes the new cost basis of the asset.
Subsequent reversal of impairment losses is not permitted.”

Simpson Thacher & Bartlett

April 12, 2023 -5- Division of Corporation Finance

U.S. Securities and Exchange Commission

Revenue Recognition

Mining Pool Services, page F-24

 2. We
                                            note your response to prior comment 3 in your March 1, 2023 letter, which you provided
                                            to clarify your response to comment 9 in your December 30, 2022 letter. Please tell
                                            us the following:

 • Such
                                            responses appear to indicate that you have concluded under ASC 606, step 2 that you have
                                            a single promise – to validate a block – and therefore a single performance obligation.
                                            Please confirm whether our understanding is correct.

 • Such
                                            responses also appear to indicate that you believe under ASC 606-10-25-4 a contract is wholly
                                            unperformed until you validate a block. Please confirm whether our understanding is correct.
                                            If our understanding is correct, please revise the ASC 606-10-25-4 analysis provided in your
                                            December 30, 2022 response to comment 9 to clarify, if true, that you have concluded
                                            computing power is not a good or service you promised to provide under your contract. Also
                                            clarify what the phrase “transaction verification services” refers to in that
                                            response as the sentence that references it also refers to computing power and to validating
                                            a block.

 • Such
                                            responses further appear to indicate that you have concluded that a contract both commences
                                            and is completed when you validate a block. Please confirm whether our understanding is correct.

  The Company respectfully submits the following:

 • The Company confirms that it has concluded that under ASC 606, step
2 that the mining pool service arrangement has a single promise, which is to validate a block, and therefore a single performance obligation.

 • The Company confirms that it has concluded that under ASC 606-10-25-4
a contract is wholly unperformed until a block is validated. The Company revises the ASC 606-10-25-4 analysis provided in December 30,
2022 response to comment 9 with respect to the following paragraph:

Simpson Thacher & Bartlett

April 12, 2023 -6- Division of Corporation Finance

U.S. Securities and Exchange Commission

“The Company has considered ASC 606-10-25-4 and concluded
that a contract does not exist upon the Company initially providing computing power to the blockchain to solve an algorithm because upon
commencing the transaction validation service and before successfully verifying a block (that is, before the transfer of the promised
performance obligation which is a successful block validation), the Company still has the unilateral right to terminate the service without
compensating the blockchain.”

The above paragraph should be revised as follows:

“The
Company has considered ASC 606-10-25-4 and concluded that a contract does not exist upon the Company initially providing computing power
to the blockchain to solve an algorithm because upon providing the computing power and before successfully verifying a block (that is,
before the transfer of the promised performance obligation which is a successful block validation), the Company still has the unilateral
right to terminate the service without compensating the blockchain. Computing power is not a good or service the Company
promised to provide under the arrangement with the blockchain. Instead, transaction verification service, or the service to validate
blocks, is the promised service under the arrangement.”

 • The Company confirms that it has concluded that a contract both commences
and is completed when the Company validates a block.

 3. As
                                            the preceding comment indicates, we continue to evaluate your conclusions related to contract
                                            inception and contract duration. However, we believe that your accounting policy to measure
                                            noncash consideration at a point other than contract inception does not comply with ASC 606-10-32-21
                                            and should be corrected.

The Company respectfully acknowledges the Staff’s
comment.

With regard to the measurement of
the noncash considerations in the mining pool service arrangements, the Company has carefully evaluated the Staff comment and
determined that its current practice to measure noncash consideration at a point other than contract inception does not comply with
ASC 606-10-32-21. Based on a recalculation of the fair value of noncash considerations at contract inception, the Company determined
that the error is both quantitatively and qualitatively immaterial to the financial statements for the year ended December 31,
2021.

The Company has corrected the error in accounting policy by measuring the noncash considerations at contract inception for the year ended
December 31, 2022. Furthermore, the Company decided not to revise the 2021 financial statements when filing its annual report on Form
20-F for the year ended December 31, 2022 because the error does not impact the consol

CORRESP
1
filename1.htm

    Simpson Thacher & Bartlett

    icbc tower, 35th floor

    3 garden road, central

    hong kong

    telephone: +852-2514-7600

    facsimile: +852-2869-7694

    Direct Dial Number

    +852-2514-7620

    E-mail Address

    ygao@stblaw.com

April 4, 2023

CONFIDENTIAL AND VIA EDGAR

Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Kathleen Collins

Ms. Megan Akst

 Re: BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed April 7, 2022

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited (the
 “Company”), we are submitting this letter in response to your correspondence dated March 22, 2023 (the “March
22 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on April 7,
2022.

In the March 22 Letter, you requested that the
Company respond to the Staff’s comments within 10 business days or advise the Staff as soon as possible when the Company will respond.
The Company respectfully advises the Staff that it is working on its responses and that it will require additional time in order to respond
fully to your letter.

The Company is therefore requesting an extension
until April 12, 2023 and expects to respond no later than that date.

*	*	*

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    christopher
    k.s. wong

    resident
                     partners

    simpson
    thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson Thacher & Bartlett

    April 4, 2023
    -2-

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

In the meantime, please do not hesitate to contact
me at +852-2514-7620 (work) or ygao@stblaw.com (email).

    Very truly yours,

    /s/ Yi Gao

    Yi Gao

 cc: Xianfeng Yang, Chief Executive Officer

Qiang Yuan, Chief Financial Officer

Bo Yu, Chairman, Chief Operating Officer

Man San Vincent Law, Executive Director

BIT Mining Limited

Danielle Bian, Partner

MaloneBailey, LLP

United States securities and exchange commission logo
March 22, 2023
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 7, 2022
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your March 1, 2023 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
February 15, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Cryptocurrency Assets, page F-18
1.We note your response to prior comment 2 where you state that you use the price quoted
each day at 0:00 UTC to determine the fair value used for impairment assessment. We do
not believe your accounting policy complies with ASC 350-30-35-19, which states in part,
“If the carrying amount of an intangible asset exceeds its fair value, an entity shall
recognize an impairment loss in an amount equal to that excess.”  As such, we believe
your accounting policy represents an “error in previously issued financial statements” that
should be corrected.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 March 22, 2023 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
March 22, 2023
Page 2
Revenue Recognition
Mining Pool Services, page F-24
2.We note your response to prior comment 3 in your March 1, 2023 letter, which you
provided to clarify your response to comment 9 in your December 30, 2022 letter.  Please
tell us the following:
•Such responses appear to indicate that you have concluded under ASC 606, step 2
that you have a single promise – to validate a block – and therefore a single
performance obligation.  Please confirm whether our understanding is correct.
•Such responses also appear to indicate that you believe under ASC 606-10-25-4 a
contract is wholly unperformed until you validate a block.  Please confirm whether
our understanding is correct.  If our understanding is correct, please revise the ASC
606-10-25-4 analysis provided in your December 30, 2022 response to comment 9 to
clarify, if true, that you have concluded computing power is not a good or service you
promised to provide under your contract.  Also clarify what the phrase “transaction
verification services” refers to in that response as the sentence that references it also
refers to computing power and to validating a block.
•Such responses further appear to indicate that you have concluded that a contract both
commences and is completed when you validate a block.  Please confirm whether our
understanding is correct.
3.As the preceding comment indicates, we continue to evaluate your conclusions related to
contract inception and contract duration. However, we believe that your accounting policy
to measure noncash consideration at a point other than contract inception does not comply
with ASC 606-10-32-21 and should be corrected.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yi Gao

CORRESP
1
filename1.htm

    Simpson Thacher & Bartlett

    icbc tower, 35th
floor

3 garden road, central

hong kong

    telephone: +852-2514-7600

facsimile:
+852-2869-7694

Direct Dial Number

E-mail Address

+852-2514-7620

ygao@stblaw.com

March 1, 2023

CONFIDENTIAL AND VIA EDGAR

Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Kathleen Collins

Ms. Megan Akst

 Re: BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed April 7, 2022

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated February 15, 2023 (the “February 15 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2021 filed with the Commission on April 7, 2022 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the February 15 Comment Letter. The Staff’s comments are retyped below in bold italic font for
your ease of reference.

    Simpson Thacher & Bartlett

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    -2-
    March 1, 2023

Form 20-F for the Fiscal Year Ended December
31, 2021

Item 8. Financial Information

Note 2. Summary of Significant Accounting Policies, page F-15

 1. We note your response to prior comment 4. Please tell the consideration given to acquire the USDT that is used to pay certain
expenses and acquire certain intangible assets. To the extent you purchase USDT in exchange for cryptocurrency assets held, tell us how
you consider any difference between the fair value of the cryptocurrency used to purchase the USDT and its carrying value at the time
of purchase in determining whether a gain or loss should be recognized. In this regard, clarify whether the gain on disposal of cryptocurrencies
in fiscal 2021 relates to the purchase of USDT to pay expenses and acquire assets.

 In response to the Staff’s comment, the Company respectfully
advises the Staff that the USDT used to pay certain expenses and acquire certain intangible assets was approximately US$2.3 million for
the year ended December 31, 2021. The entire amount of such USDT was acquired from advance payments from the Company’s customers
for data center service fees and deposits which were priced in fiat currencies in the contracts and the Company accepted such payments
in the form of USDT. The Company did not purchase such USDT in exchange for cryptocurrency assets held.

The Company further clarifies that the net gain on disposal of cryptocurrencies
in the amount of US$6.7 million during 2021 was primarily related to the Company’s mining pool business. The Company distributed
mining rewards to the pool participants and recognized the difference between the carrying amount of the cryptocurrencies distributed
and the carrying amount of the accounts payable settled as the gain or loss on disposal of cryptocurrencies, in accordance with ASC 610-20.

Cryptocurrency Assets, page F-18

 2. Your response to prior comment 5 continues to make conflicting representations. In this regard, you state that in determining
if an impairment has occurred under ASC 350, you consider the “lowest quoted price of one unit of cryptocurrency asset since acquiring
the cryptocurrency asset” but you also state that in practice you measure fair value of your cryptocurrency assets using the quoted
price at 0:00 UTC. Please confirm that you recognize impairment whenever carrying value exceeds fair value. Also clarify whether you use
the lowest fair value during the reporting period to measure such impairment. If you use a different fair value, such as the fair value
at 0:00 UTC, please correct your policy to comply with ASC 350-30-35-19 and tell us whether such correction was material to any historical
period presented.

    Simpson Thacher & Bartlett

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    -3-
    March 1, 2023

The Company respectfully advises the Staff that in determining if an
impairment has occurred, the Company considers the daily quoted price of one unit of cryptocurrency asset, and utilizes the price which
is the lowest among all daily prices quoted since the cryptocurrency asset was acquired to determine the fair value used for impairment
assessment. If the then-current carrying value of the units of cryptocurrency exceeds their fair value so determined, an impairment loss
has occurred with respect to such units of cryptocurrency in the amount equal to the difference between their carrying value and their
fair value. It is the Company’s policy to use the price quoted each day at 0:00 UTC as the daily price. The Company considers such
practice to be consistent with ASC 350-30-35-19, as the Company performs the comparison of the cryptocurrency asset’s carrying amount
and its fair value based on the daily price.

Furthermore, the Company calculated the
impairment loss for the cryptocurrency assets held as of December 31, 2021 by using the lowest price quoted during each day since their
acquisition as their fair value used in the impairment assessment and compared the impairment result with that based on the Company’s
current practice, noting that impairment loss calculated using the lowest quoted price of one unit of cryptocurrency asset since acquiring
the cryptocurrency asset is larger than the current impairment loss recorded by approximately US$1.9 million. Such a difference represents
approximately 3.5% of the Company’s total cryptocurrency assets balance, or 0.7% of the Company’s total assets as of December
31, 2021. Accordingly, the Company concluded that such difference is not material to its historical periods presented in the Annual Report.

 The Company proposes to revise and include the following
accounting policy in its future filings to further clarify the Company’s practice with respect to determining the fair value used
in the impairment assessment:

“Cryptocurrencies held are accounted for as intangible assets
with indefinite useful lives. An intangible asset with an indefinite useful life is not amortized but assessed for impairment quarterly,
or more frequently, when events or changes in circumstances occur, principally decreases in the quoted prices of the cryptocurrencies,
indicating that it is more likely than not that the indefinite-lived asset is impaired. In determining if an impairment has occurred,
the Company considers the daily quoted price of one unit of cryptocurrency asset, and utilizes the price which is the lowest among all
daily prices quoted since the cryptocurrency asset was acquired to determine the fair value used for impairment assessment. The Company
uses the price quoted each day at 0:00 Coordinated Universal Time (“UTC”) as the daily price. If the then-current carrying
value of the units of cryptocurrency exceeds their fair value so determined, an impairment loss has occurred with respect to such units
of cryptocurrency in the amount equal to the difference between their carrying value and their fair value. To the extent an impairment
loss on a cryptocurrency is recognized, the loss establishes the new cost basis of the cryptocurrency asset. Subsequent reversal of impairment
losses is not permitted.”

    Simpson Thacher & Bartlett

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    -4-
    March 1, 2023

Revenue Recognition

Mining Pool Services, page F-24

 3. You state in your response to prior comment 9 and in your proposed revised disclosures in prior comment 11 that revenue is measured
at the fair value of rewards using the quoted price of the related cryptocurrency at contract inception. However, you also state that
in practice you use the price of cryptocurrency at 0:00 UTC each day to measure such fair value, which does not comply with ASC 606-10-32-21.
Please correct your policy to comply with GAAP and ensure that your disclosures appropriately convey at what point you measure the fair
value of the noncash consideration.

The Company respectfully advises the Staff
that, as noted above in the response to comment 2, it is the Company’s policy to use the price quoted each day at 0:00 UTC as the
fair value of the cryptocurrency asset on the particular day. For blocks successfully validated on a certain day (i.e. contracts whose
inception date is on the same day), the Company has been consistently measuring its revenues using the daily price quoted on a given day.
The Company considers such practice to be appropriate under ASC 606-10-32-21, as the daily price quoted on the date of the contract’s
inception is used.

Furthermore, the Company respectfully
advises the Staff that is technically infeasible for the Company to obtain the price quoted at the specific time of each
contract’s inception. As block validations are successfully completed at various different times throughout any given day, the
Company believes that the fair value measured by using an average of quoted prices would best approximate the fair value of rewards
calculated using the price quoted at the specific time of each contract’s inception. The Company has performed an analysis
utilizing the average of quoted prices during the day to calculate the fair value of rewards, noting the difference between the
revenues calculated using the average price of each day and the mining pool service revenues recorded by the Company is
approximately 0.5% of the Company’s total mining pool service revenues for the year ended December 31, 2021. Accordingly, the
Company concluded that such difference is not material.

The Company proposes to revise and include
the following accounting policy in its future filings to further clarify the Company’s mining pool services and its practice with
respect to measurements of the noncash consideration:

“Mining Pool Services

The Group considers itself the principal
in transactions with the blockchain networks and recognizes mining pool revenue on a gross basis. A contract with the blockchain for block
rewards, or with a transaction requester for transaction verification fees, exists upon the transfer of a verified block to the blockchain.
The performance obligation is to validate each block. Revenue is recognized at the point when the block validation is successfully completed,
which is also when the Group receives the rewards. Revenue is measured at the fair value of rewards received using the daily price of
the related cryptocurrency quoted on the date of the contract’s inception. The Company uses the price quoted each day at 0:00 Coordinated
Universal Time (“UTC”) as the daily price.”

    Simpson Thacher & Bartlett

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    -5-
    March 1, 2023

 4. In your proposed disclosure revisions under prior comment 11 you state that "revenue is recognized at the point when the
block validation is successfully completed and the Group has received the rewards." Please clarify whether you receive the rewards
at the time the block is validated and revise your disclosures accordingly.

The Company respectfully confirms that
it receives the rewards at the time when the block is validated.

The Company proposes to revise the accounting
policy as follows:

“Mining pool services

The Group considers itself the principal
in transactions with the blockchain networks and recognizes mining pool revenue on a gross basis. A contract with the blockchain for block
rewards, or with a transaction requester for transaction verification fees, exists upon the transfer of a verified block to the blockchain.
The performance obligation is to validate each block. Revenue is recognized at the point when the block validation is successfully completed,
which is also when the Group receives the rewards. Revenue is measured at the fair value of rewards received using the daily price of
the related cryptocurrency quoted on the date of the contract’s inception. The Company uses the price quoted each day at 0:00 Coordinated
Universal Time (“UTC”) as the daily price.”

*    *    *

    Simpson Thacher & Bartlett

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    -6-
    March 1, 2023

If you have any question regarding the Company’s
responses to the Staff’s comments, please do not hesitate to contact me at +852-2514-7620 (work), +852-6588-7136 (mobile) or ygao@stblaw.com
(email).

    Very truly yours,

    /s/ Yi Gao

    Yi Gao

cc:
Xianfeng Yang, Chief Executive Officer

 Qiang Yuan, Chief Financial Officer
 Bo
Yu, Chairman, Chief Operating Officer
 Man San Vincent Law, Executive Director

BIT Mining Limited

    Danielle Bian, Partner

    MaloneBailey LLP

United States securities and exchange commission logo
February 15, 2023
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 7, 2022
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your December 30, 2022 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
November 15, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 8. Financial Information
Note 2. Summary of Significant Accounting Policies, page F-15
1.We note your response to prior comment 4.  Please tell the consideration given to acquire
the USDT that is used to pay certain expenses and acquire certain intangible assets.  To
the extent you purchase USDT in exchange for cryptocurrency assets held, tell us how you
consider any difference between the fair value of the cryptocurrency used to purchase the
USDT and its carrying value at the time of purchase in determining whether a gain or loss
should be recognized. In this regard, clarify whether the gain on disposal of
cryptocurrencies in fiscal 2021 relates to the purchase of USDT to pay expenses and
acquire assets.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 February 15, 2023 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
February 15, 2023
Page 2
Cryptocurrency Assets, page F-18
2.Your response to prior comment 5 continues to make conflicting representations. In this
regard, you state that in determining if an impairment has occurred under ASC 350, you
consider the “lowest quoted price of one unit of cryptocurrency asset since acquiring the
cryptocurrency asset” but you also state that in practice you measure fair value of your
cryptocurrency assets using the quoted price at 0:00 UTC.   Please confirm that you
recognize impairment whenever carrying value exceeds fair value.  Also clarify whether
you use the lowest fair value during the reporting period to measure such impairment.  If
you use a different fair value, such as the fair value at 0:00 UTC, please correct your
policy to comply with ASC 350-30-35-19 and tell us whether such correction was material
to any historical period presented.
Revenue Recognition
Mining Pool Services, page F-24
3.You state in your response to prior comment 9 and in your proposed revised disclosures in
prior comment 11 that revenue is measured at the fair value of rewards using the quoted
price of the related cryptocurrency at contract inception.  However, you also state that in
practice you use the price of cryptocurrency at 0:00 UTC each day to measure  such fair
value, which does not comply with ASC 606-10-32-21.  Please correct your policy to
comply with GAAP and ensure that your disclosures appropriately convey at what point
you measure the fair value of the noncash consideration.
4.In your proposed disclosure revisions under prior comment 11 you state that "revenue is
recognized at the point when the block validation is successfully completed and the Group
has received the rewards."  Please clarify whether you receive the rewards at the time the
block is validated and revise your disclosures accordingly.
            You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Branch Chief at 202-551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yi Gao

CORRESP
1
filename1.htm

    Simpson
                    Thacher & Bartlett

    icbc
    tower, 35th floor

    3
    garden road, central

    hong
    kong

    telephone:
                    +852-2514-7600

    facsimile:
    +852-2869-7694

    Direct
                                            Dial Number

    +852-2514-7620

    E-mail
                                            Address

    ygao@stblaw.com

    December 30, 2022

    CONFIDENTIAL AND VIA EDGAR

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Attention:
    Ms. Kathleen Collins

    Ms. Megan Akst

 Re: BIT Mining Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed April 7, 2022

File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated November 15, 2022 (the “November 15 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2021 filed with the Commission on April 7, 2022 (the “Annual Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the November 15 Comment Letter. The Staff’s comments are retyped below in bold italic font for
your ease of reference.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
      ADAM
    S. GOLDBERG
      MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    kathryn
    kING  sudol
    christopher
    k.s. wong

resident
partners

simpson
thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

     Simpson Thacher & Bartlett

December 30, 2022 -2-  Division of Corporation Finance

U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December
31, 2021

Item 3. Key Information, page 3

 1. We note your response to prior comment 2. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment to your current Form 20-F.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“BIT Mining Limited, our ultimate Cayman
Islands holding company, does not have substantive operations other than (1) holding certain of our digital assets in connection with
our cryptocurrency mining business and (2) indirectly holding the equity interest in our subsidiaries in Hong Kong, British Virgin Islands,
Canada, Malta, Cyprus, Curacao, Kazakhstan, the United States and China. As of the date of this annual report, (i) we do not have revenue-generating
operations in China, and our remaining operations in China primarily involve the provision of administrative support to our cryptocurrency
mining business as well as the provision of internal information technology services to our operating entities and mining pools outside
China; and (ii) we do not maintain any variable interest entity structure in China. Adverse actions by the Chinese government may potentially
force us to cease our administrative support and internal information technology services from China to your international cryptocurrency
mining business. We have developed Ethereum mining operation in Hong Kong, but have no plan to further expand such Hong Kong-based operation.
This is because we are focusing on growing our cryptocurrency mining operations in the United States. In 2019, 2020 and 2021, our operations
in Hong Kong generated approximately nil, nil and 1.4% of our total revenue for such year. As used in this annual report, “we,”
 “us,” “our company” or “our” refers to BIT Mining Limited, a Cayman Islands exempted company and its
subsidiaries. Investors in our ADSs are purchasing equity interest in a Cayman Islands holding company.

“The following diagram illustrates
our company’s organizational structure, and the place of formation, ownership interest and affiliation of each of our principal
subsidiaries and affiliated entities as of the date of this annual report. BIT Mining Limited, in which investors hold an interest, is
shared in grey.”

 2. We note your response to prior comment 3. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“Cash can be transferred between our
holding company in Cayman Islands and our subsidiaries in China and other regions and countries through intercompany fund advances and
capital contributions.

     Simpson Thacher & Bartlett

December 30, 2022 -3-  Division of Corporation Finance

U.S. Securities and Exchange Commission

“As of the date of this annual report,
BIT Mining Limited has not distributed any earnings to its subsidiaries or the former VIEs. BIT Mining Limited currently does not have
any plan to distribute earnings to our subsidiaries in the foreseeable future. No transfers, dividends, or distributions have been made
to date to U.S. investors.

“In 2019, 2020 and 2021, BIT Mining
Limited transferred cash to our subsidiaries of RMB9.4 million, nil and RMB426.1 million, respectively, through intercompany fund advances
and capital contributions. BIT Mining Limited transferred cash to the former VIEs of RMB56.8 million, RMB27.9 million and RMB8.8 million,
respectively, through intercompany fund advances and long-term loan, which was interest free and without recourse. Our wholly-owned subsidiaries
in China transferred cash to the former VIEs of RMB102.7 million, RMB10,000 and RMB2.8 million, respectively, through short-term loan,
which was interest free and without recourse. Furthermore, in 2021 and up to the date of this annual report, our subsidiaries in China
transferred certain cryptocurrency mining assets and equipment to our overseas subsidiaries, which was a part of our business strategy
to migrate our cryptocurrency mining business out of China.

“In 2019, 2020 and 2021, the former
VIEs transferred cash to our wholly-owned subsidiaries of RMB2.8 million, RMB8.3 million and RMB186.9 million, respectively, pursuant
to our former contractual arrangements.

“The aforementioned cash and assets
transfers among our Cayman holding company, subsidiaries and the former VIEs were for business operation purposes. As of the date of this
annual report, a substantial majority of our assets and cash are located outside of China. We are not aware of any regulatory restrictions
of transferring funds between our Cayman Islands holding company and subsidiaries in Hong Kong, British Virgin Islands, Canada, Malta,
Cyprus, Curacao, Kazakhstan and the United States. We are subject to applicable PRC regulation of loans to or investment in subsidiaries
in China.”

 3. We note your response to prior comment 4. Please provide us with the proposed disclosure that you intend to include in your
next Form 20-F, including any amendment.

In response to the Staff’s comment,
the Company intends to include the following proposed disclosure in its next annual report on Form 20-F for the fiscal year ending December
31, 2022. The Company does not intend to amend the Annual Report.

“We face various legal and operational
risks and regulatory uncertainties associated with having certain non revenue-generating subsidiaries, certain administrative personnel,
and certain members of the board of directors located in China. The PRC government has significant authority to exert influence on the
ability of a company located in China to conduct its business, accept foreign investments or list on U.S. or other foreign exchanges.
We cannot assure you that such influence will not be extended to companies operating in Hong Kong, such as our Hong Kong subsidiaries.
We may have to scale down or cease our remaining operations in China and our Ethereum mining operation in Hong Kong, if the PRC government
extends its influence and/or control in Hong Kong to restrict or otherwise regulate our remaining operations in China and our Ethereum
mining operation in Hong Kong. For example, we face risks and uncertainties associated with regulatory approvals of offshore offerings
and oversight on cybersecurity and data privacy. Such risks and uncertainties could
result in a material change in our operations and/or the value of the ADSs or could significantly limit or completely hinder our ability
to offer ADSs and/or other securities to investors and cause the value of such securities to significantly decline or be worthless. The
PRC government also has significant discretion over our business operations in China, and may intervene with or influence our China-based
operations as it deems appropriate to further regulatory, political and societal goals. Furthermore, the PRC government has recently indicated
an intent to exert more oversight and control over overseas securities offerings and foreign investments in China-based companies. These
regulatory risks and uncertainties could become applicable to our Hong Kong operations if regulatory authorities in Hong Kong adopt similar
rules and/or regulatory actions. Any adverse action, once taken by the PRC and/or Hong Kong government, could significantly limit or completely
hinder our ability to offer securities to investors and cause the value of such securities to significantly decline or in extreme cases,
become worthless.

     Simpson Thacher & Bartlett

December 30, 2022 -4-  Division of Corporation Finance

U.S. Securities and Exchange Commission

“Our U.S.-based auditor, MaloneBailey,
LLP, is not among the PCAOB-registered public accounting firms headquartered in the PRC or Hong Kong that are subject to PCAOB’s
determination on December 16, 2021 of having been unable to inspect or investigate completely. As of the date of this annual report, we
have not been identified by the SEC as a commission-identified issuer under the Holding Foreign Companies Accountable Act (“HFCA
Act”). However, we could still face the risk of delisting and cease of trading of our securities from a stock exchange or an over-the-counter
market in the United States under the HFCA Act and the securities regulations promulgated thereunder if the PCAOB determines in the future
that it is unable to completely inspect or investigate our auditor which has a presence in China.”

Item 8. Financial Information

Note 2. Summary of Significant Accounting Policies, page F-15

 4. We note your response to prior comment 13. Please tell us how you considered the guidance in ASC 350-10-40-1 in determining
that transactions involving the payment of expenses or the acquisition of assets in exchange for cryptocurrency should be accounted for
in accordance with ASC 845. Also, tell us how you determined that no gain or loss is recognized in such transactions and specifically
address situations in which the fair value of the cryptocurrency exchanged exceeded the carrying value. Lastly, revise your proposed accounting
policy to eliminate the reference to "generally" and describe the circumstance in which the transfer would not be based on fair
value or revise as necessary.

The Company respectfully acknowledges the
Staff’s comment and has reassessed the accounting for transactions involving the payment of expenses or the acquisition of assets
in exchange for cryptocurrency as follows.

The Company has considered ASC 350-10-40-1
which indicates that an entity shall account for the derecognition of a nonfinancial asset in accordance with ASC 610-20 unless a scope
exception from ASC 610-20 applies. Based on ASC 610-20-15-4, the scope exception includes nonmonetary transactions within the scope of
ASC 845. The Company has further analyzed under ASC 845-10-15-4 that the transfer of a nonfinancial asset within the scope of ASC 610-20
in exchange for noncash consideration would be scoped out from ASC 845. As a result, the Company concluded that transactions involving
the payment of expenses or the acquisition of assets in exchange for cryptocurrency should be accounted for under ASC 610-20.

     Simpson Thacher & Bartlett

December 30, 2022 -5-  Division of Corporation Finance

U.S. Securities and Exchange Commission

Pursuant to ASC 610-20, as the Company
does not hold controlling financial interests in any of the counterparties in the transactions, it evaluates the transactions in accordance
with ASC 610-20-25-5 through 25-7. The Company has concluded that contracts that meet all of the criteria in ASC 606-10-25-1 exist, and
the counterparties have obtained control of the cryptocurrencies. Therefore, in those transactions, the Company has met the criteria to
derecognize the cryptocurrencies. In accordance with ASC 610-20-32-2 through 32-3, the Company should recognize a gain or loss for the
difference between the amount of consideration measured and allocated to that asset and the carrying amount of the distinct asset. The
amount of consideration includes both the transaction price to be determined following ASC 606-10-32-2 through 32-27 and the carrying
amount of liabilities assumed or relieved by a counterparty.

The Company respectfully advises the Staff
that the nature of the Company’s transactions is mainly the transfers of USDT to pay off hosting expenses charged by third-party
mining data centers which host the Company’s mining machines and to acquire certain intangible asset. The relevant contracts were
priced in fiat currencies and the counterparties accepted the payments in the form of USDT. For these transactions, as the nature of the
transfer of cryptocurrencies is to settle existing liabilities, the amount of consideration is the carrying amount of liabilities relieved
by the counterparties in accordance with ASC 610-20-32-5.

As the value of USDT pegs to US dollar
and is relatively stable, the carrying amount of the USDT transferred approximates the amount of consideration. Therefore, the Company
did not record any gain or loss on such transactions. The reassessed accounting treatment has no impact to the financial statements.

The Company proposes to add the following
revised disclosure under the accounting policy of cryptocurrency assets.

“Cryptocurrency assets

The Company also enters into transactions
to transfer cryptocurrencies to pay for operating expense and to acquire certain assets. Such transactions are accounted for in accordance
with ASC 610-20, “Other Income - Gains and Losses from the Derecognition of Nonfinancial Assets”. Under ASC 610-20, if the
Group does not have a controlling financial interest in the entity that holds the cryptocurrency and the arrangement meets the criteria
to be accounted for as a contract, the Group would de-recognize the cryptocurrency and recognize a gain or loss on the transfer of the
cryptocurrency when control of the cryptocurrency transfers to the counterparty. The gain or loss is measured as the difference between
the amount of consideration allocated to the cryptocurrency and its carrying amount. For the year ended December 31, 2021, the gain or
loss recorded on such transactions was nil.”

Cryptocurrency Assets, page F-18

 5. Your response to prior comment 14 appears to make conflicting representations. In this regard, you state that you recognize
impairment "whenever the car

CORRESP
1
filename1.htm

Simpson Thacher & Bartlett

icbc
tower, 35th floor

3
garden road, central

hong
kong

 _____________

telephone:
+852-2514-7600

facsimile:
+852-2869-7694

    Direct
                           Dial Number

    +852-2514-7620

    E-mail
                           Address

    ygao@stblaw.com

December
8, 2022

CONFIDENTIAL
AND VIA EDGAR

Division of Corporation
Finance

U.S. Securities
and Exchange Commission

100 F Street,
N.E.

Washington, D.C.
20549

    Attention:
    Ms. Kathleen Collins

    Ms. Megan Akst

 Re: BIT
                                            Mining Limited

                                            Form 20-F for the Fiscal Year Ended December 31, 2021

                                            Filed April 7, 2022

                                            File No. 001-36206

Ladies and Gentlemen:

On behalf of our
client, BIT Mining Limited (the “Company”), we are submitting this letter in response to your correspondence dated
November 15, 2022 (the “November 15 Letter”) concerning the above-referenced annual report on Form 20-F that the Company
filed with the Commission on April 7, 2022.

In the November
15 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff as soon as
possible when the Company will respond. The Company respectfully advises the Staff that it is working on its responses and that it will
require additional time in order to respond fully to your letter.

The Company is therefore
requesting an extension until December 30, 2022 and expects to respond no later than that date.

*	          *	         *

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    christopher
    k.s. wong

    resident
                     partners

    simpson
    thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson
                    Thacher & Bartlett

    December
    8, 2022
    -2-
    Division
                                            of Corporation Finance

    U.S.
    Securities and Exchange Commission

In the meantime,
please do not hesitate to contact me at +852-2514-7620 (work) or ygao@stblaw.com (email).

    Very truly yours,

    /s/ Yi Gao

    Yi Gao

    cc:
    Xianfeng Yang, Chief Executive Officer

    Qiang Yuan, Chief Financial Officer

    Bo Yu, Chairman, Chief Operating Officer

    Man San Vincent Law, Executive Director

    BIT Mining Limited

    Danielle Bian, Partner

    MaloneBailey, LLP

United States securities and exchange commission logo
November 15, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 7, 2022
File No. 001-36206
Dear Xianfeng Yang:
            We have reviewed your September 6, 2022 response to our comment letter 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 22, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31. 2021
Item 3. Key Information, page 3
1.We note your response to prior comment 2.  Please provide us with the proposed
disclosure that you intend to include in your next Form 20-F, including any amendment to
your current Form 20-F.
2.We note your response to prior comment 3.  Please provide us with the proposed
disclosure that you intend to include in your next Form 20-F, including any amendment.
3.We note your response to prior comment 4.  Please provide us with the proposed
disclosure that you intend to include in your next Form 20-F, including any amendment.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 November 15, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
November 15, 2022
Page 2
Item 8. Financial Information
Note 2. Summary of Significant Accounting Policies, page F-15
4.We note your response to prior comment 13.  Please tell us how you considered the
guidance in ASC 350-10-40-1 in determining that transactions involving the payment of
expenses or the acquisition of assets in exchange for cryptocurrency should be accounted
for in accordance with ASC 845.  Also, tell us how you determined that no gain or loss is
recognized in such transactions and specifically address situations in which the fair value
of the cryptocurrency exchanged exceeded the carrying value. Lastly, revise your
proposed accounting policy to eliminate the reference to "generally" and describe the
circumstance in which the transfer would not be based on fair value or revise as
necessary.
Cryptocurrency Assets, page F-18
5.Your response to prior comment 14 appears to make conflicting representations.  In this
regard, you state that you recognize impairment "whenever the carrying value for the
cryptocurrency is below fair value."  However, you also indicate that you use the open
price at around 0:00 UTC of the day from bitfinex.com and coinmarketcap.com as fair
value for purposes of assessing impairment of your ASC 350 intangible assets. In addition
your proposed disclosures continues to include the phrase "at the time its fair value is
being measured." Please reconcile this apparent inconsistency. To the extent that you do
not recognize impairment whenever fair value is below carrying value, explain why you
believe the policy complies with ASC 350-30-35-19. Lastly, clarify whether the "source
for fair value determination" included in your response is your principal market. Refer
to ASC 820-10-35-5 and 35-5A.
Revenue Recognition
General, page F-23
6.We note your reference on page F-25 to Note 24 with regard to your disaggregated
revenue data.  Please revise to provide disaggregated revenue information related to
revenue earned from outside of the consolidated group and explain the relationship of the
disaggregation of revenue earned from outside of the consolidated group to the revenue
information disclosed for each reportable segment.  Refer to ASC 606-10-50-5 and 50-6.
Crytpocurrency Mining, page F-23
7.Please clarify for us whether cryptocurrency mining revenue is eliminated in consolidation
for each reporting period presented and subsequent periods.  To this end, your disclosure
suggests that cryptocurrency mining revenue is generated solely from providing
computing power to a consolidated subsidiary, BTC.com.  If cryptocurrency mining
activities are eliminated in your consolidated financial statements and the policy only
relates to a reportable segment, revise your footnote disclosure to include it in an
appropriate context.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 November 15, 2022 Page 3
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
November 15, 2022
Page 3
8.We will continue to consider your responses to our prior comments 12 and 15-18 based on
your responses to our comments herein.
Mining Pool Services, page F-24
9.Please provide an accounting analysis of ASC 606 step 1 for the transaction verification
services you provide, including your consideration of ASC 606-10-25-4.  For example,
you state in your response to prior comment 21 that each creation of a block is a new
contract, and the contract duration is “the time period from the creation of a block to the
successful placement of that block.”   In your response, you describe a practice that is
inconsistent with this statement. It is also unclear whether this statement means that an
ASC 606 contract exists only for each block attempt and, for each block attempt, only
commences when you start providing transaction verification services.
10.In order to help us evaluate your response to prior comment 21 related to recognition,
please reconcile your policy of not recognizing revenue until “the Group has received the
rewards” to ASC 606.  Include in your reply, but do not limit it to, your consideration of
ASC 606-10-32-4 upon successful placement of a block on a blockchain.
11.Please reconcile the table in response to comment 21 where you describe the timing of
receipt of cryptoassets upon your successful placement of a block on the blockchain and
the paragraph that follows it.
Cost of Services, page F-25
12.You state in your response to prior comment 20 that costs of mining pool services
include "other direct costs" such as server fees and labor for maintaining the mining pool
services.  Please tell us, and revise to clarify, whether other costs, such as electrical power,
depreciation and amortization, etc. are included in such costs.
Note 19. Related Party Transactions, page F-56
13.Your response to prior comment 22 refers to disclosures in Note 22, however, such
disclosures do not appear to address the December 21, 2020 subscription agreement with
Good Luck Information as described on page 46.  Please explain and provide us with the
disclosures that you intend to include in future filings.
Note 24. Segment Reporting, page F-63
14.Please revise to separately disclose revenue from your external customers and revenue
from transactions with other operating segments within the consolidated entity and include
the elimination of any intersegment revenues in your reconciliation of the reportable
segments, revenues and profit and loss.  Refer to ASC 280-10-50-22(a) and (b) and 50-30.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 November 15, 2022 Page 4
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
November 15, 2022
Page 4
            You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Branch Chief at 202-551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
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September 6, 2022

CONFIDENTIAL AND VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Ms. Kathleen Collins

    Ms. Megan Akst

 Re: BIT
                                            Mining Limited

                                            Form 20-F for the Fiscal Year Ended December 31, 2021

                                            Filed April 7, 2022

                                            File No. 001-36206

Ladies and Gentlemen:

On behalf of our client, BIT Mining Limited, a
company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments contained in the
letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated August 22, 2022 (the “August 22 Comment Letter”) relating to the Company’s annual report on
Form 20-F for the fiscal year ended December 31, 2021 filed with the Commission on April 7, 2022 (the “Annual
Report”).

Set forth below are the Company’s responses
to the Staff’s comments in the August 22 Comment Letter. The Staff’s comments are retyped below in bold italic font
for your ease of reference.

michael j.c.M. ceulen marjory j. ding daniel fertig adam C. furber YI GAO   ADAM S. GOLDBERG   MAKIKO HARUNARI Ian C. Ho JONATHAN HWANG anthony d. king jin hYUK park kathryn kING  sudol christopher k.s. wong

resident partners

simpson thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

New York Beijing Brussels Houston LONDON Los Angeles Palo Alto SÃO PAULO TOKYO Washington, D.C.

Simpson Thacher & Bartlett

September 6, 2022 -2- Division of Corporation Finance

U.S. Securities and Exchange Commission

Form 20-F for the Fiscal Year Ended December 31, 2021

Conventions that Apply to this Annual Report on Form 20-F, page 1

1. Please revise to your definition of “China” and
                                            the “PRC” to remove the exclusion of Taiwan, Hong Kong and Macau.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F the Company will revise its definition of “China” and the “PRC” to remove
the exclusion of Taiwan, Hong Kong and Macau.

Item 3. Key Information, page 3

2. At the onset of Part I, please disclose that you use
                                            a holding company structure and what that entails. Provide here a summary diagram of the
                                            company’s corporate structure, identifying the person or entity that owns the equity
                                            in each depicted entity. Clearly identify the entity in which investors hold an interest
                                            and the entities in which the company conducts it operations and clarify whether you conduct
                                            your current operations through any variable interest entities. Also, revise Part I
                                            to disclose, if true, that you do not have revenue-generating operations in China. Disclose
                                            that adverse actions by the Chinese government may force you to cease your administrative
                                            support and internal information technology services from China to your international cryptocurrency
                                            mining business. Clarify that you have developed Ethereum mining operations in Hong Kong
                                            and whether you have plans to further expand your Hong Kong-based operations. Lastly, disclose
                                            here the amount of revenue from your Hong Kong operations for each period presented.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F at the onset of Part I the Company will (i) disclose that it uses a holding company
structure and what that entails, (ii) provide a summary diagram of its corporate structure, identifying the person or entity that
owns the equity in each depicted entity, (iii) clearly identify the entity in which investors hold an interest and the entities
in which the Company conducts its operations, (iv) clarify that it does not conduct its current operations through any variable
interest entities, (iv) revise Part I to disclose that the Company does not have revenue-generating operations in mainland
China, (v) disclose that adverse actions by the Chinese government may force the Company to cease its administrative support and
internal information technology services from China to the Company’s international cryptocurrency mining business, (vi) clarify
that it has developed Ethereum mining operations in Hong Kong and whether the Company has any plans to further expand its Hong Kong-based
operations, and (vii) disclose the amount of revenue from its Hong Kong operations for each period presented.

Simpson Thacher & Bartlett

September 6, 2022 -3- Division of Corporation Finance

U.S. Securities and Exchange Commission

3. At the onset of Part I, please provide a clear description
                                            of how cash is transferred through your organization and disclose your intentions to distribute
                                            earnings. State whether any transfers, dividends, or distributions have been made to date between the holding company and
its subsidiaries, or to investors, and quantify the amounts where applicable and the direction of transfer. Quantify any dividends or
distributions that a subsidiary has made to the holding company, which entity made such transfer, and their tax consequences, if any.
Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure here should
make clear if no transfers, dividends, or distributions have been made to date. Also, describe in the forepart of Part I any restrictions
on foreign exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions
and limitations on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S.
investors.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F at the onset of Part I the Company will (i) provide a clear description of how cash
is transferred through its organization and disclose its intention not to distribute earnings, (ii) state whether any transfers,
dividends, or distributions have been made to date between the holding company and its subsidiaries, or to investors, and quantify the
amounts where applicable and the direction of transfer, (iii) quantify any dividends or distributions that a subsidiary has made
to the holding company, which entity made such transfer, and their tax consequences, if any, (iv) make clear that no transfers,
dividends, or distributions have been made to date to U.S. investors, (v) describe in the forepart of Part I any restrictions
on foreign exchange and the Company’s ability to transfer cash between entities, across borders, and to U.S. investors, and (vi) describe
any restrictions and limitations on the Company’s ability to distribute earnings from the company, including its subsidiaries,
to the parent company and U.S. investors.

4. Please revise the forepart of Part I to address each
                                            of the legal and operational risks associated with conducting your business in Hong Kong
                                            set forth in the sample letter to China-based companies available on our website. We refer
                                            you to your response to comment 1 in your May 6, 2022 letter. Also, ensure that your
                                            disclosures address whether your auditor is subject to the determinations announced by the
                                            PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies Accountable
                                            Act (HFCAA) and the Accelerating HFCAA and related regulations will affect your company.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F the Company will (i) revise the forepart of Part I to address each of the legal and
operational risks associated with conducting its business in Hong Kong set forth in the sample letter to China-based companies available
on the Commission’s website, and (ii) ensure that its disclosures address that the Company’s auditor is not subject
to the determinations announced by the PCAOB on December 16, 2021, and therefore, that the HFCAA, the Accelerating HFCAA and related
regulations should not affect the Company.

Simpson Thacher & Bartlett

September 6, 2022 -4- Division of Corporation Finance

U.S. Securities and Exchange Commission

Risk Factors

Because there has been limited precedent set for financial accounting of bitcoin and other cryptocurrency assets..., page 29

5. You
                                            state that "there has been limited precedent set for the financial accounting of cryptocurrencies
                                            and related revenue recognition and no official guidance has yet been provided by the FASB
                                            or the SEC, [such that] it is unclear how companies may in the future be required to account
                                            for cryptocurrency transactions and assets and related revenue recognition.” Please
                                            help us understand the basis for these statements and your accounting policies, and consider
                                            the need to revise or remove these statements.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F the Company will remove these statements.

You
will have limited ability to bring an action against us or against out directors	     ,
page 40

6. You
                                            state here that you conduct operations exclusively in China. Please reconcile this
                                            statement with your disclosures elsewhere throughout the filing where you refer to limited
                                            operations in China that relate mainly to providing administrative support to your cryptocurrency
                                            mining business outside the PRC. Please explain or revise.

In response to the Staff’s comment, in the Company’s
future annual reports on Form 20-F the Company will revise this statement.

Item 5. Operating and Financial Review and Prospects

A. Operating Results, page 62

7. Please tell us why you believe that adjusting for the impairment
                                            of cryptocurrencies and the net gain on disposal of cryptocurrencies provides useful information
                                            to investors considering the nature of your business, your strategy to hold bitcoin as an
                                            investment and sell bitcoin in future periods as needed for cash flow needs, and the recurring
                                            nature of these charges. Please explain or revise to remove these adjustments from your computation
                                            of non-GAAP adjusted net loss. Refer to Rule 100 of Regulation G.

The Company respectfully
acknowledges the Staff’s comment and will revise and exclude the impairment of cryptocurrencies and the net gain on disposal of
cryptocurrencies from the computation of non-GAAP adjusted net loss in its future filings.

Simpson Thacher & Bartlett

September 6, 2022 -5- Division of Corporation Finance

U.S. Securities and Exchange Commission

8. Please revise to include the income tax effects as a separate
                                            adjustment and expand your disclosure to clearly explain how the tax effects of the non-GAAP adjustments are calculated, or
explain why you do not believe this is necessary. Refer to Question 102.11 of the Non-GAAP C&DIs.

The Company respectfully advises the Staff that there are
no income tax effects on these non-GAAP adjustments as the effective income tax rate for these non-GAAP adjustments were zero.

9. We note you present non-GAAP measures of adjusted net loss
                                            from continuing operations attributable to Bit Mining and adjusted net income from discontinued
                                            operations attributable to Bit Mining. Please revise to include a reconciliation for each
                                            of these non-GAAP measures. Refer to Item 10(e)(1)(i)(B) of Regulation S-K.

The
Company respectfully acknowledges the Staff’s comment and below is a reconciliation for each of the non-GAAP measures:

    2019
    2020
    2021

    USD'000
    USD'000
    USD'000

    Net loss from continuing operations
      (74,850 )
      (23,324 )
      (63,566 )

    Less: Net loss from continuing operations attributable to noncontrolling interest
      -
      -
      (11,792 )

    Net loss from continuing operations attributable to BIT Mining Limited
      (74,850 )
      (23,324 )
      (51,774 )

    Adjust for continuing operations:

    Adjustment for share-based compensation expenses
      11,498
      8,047
      6,446

    Adjustment for impairment of intangible assets
      26,909
      -
      56

    Adjustment for impairment of goodwill
      19,200
      -
      -

    Adjustment for impairment of long-term investments
      1,372
      4,787
      -

    Adjustment for deferred tax benefit relating to valuation allowance
      (1,086 )
      (531 )
      (359 )

    Adjustment for gain on previously held equity interest
      -
      -
      (5,500 )

    Adjustment for impairment of property and equipment
      -
      -
      22,392

    Adjustment for impairment of cryptocurrencies
      -
      -
      31,757

    Adjustment for net gain on disposal of cryptocurrencies
      -
      -
      (6,717 )

    Adjustment for changes in fair value of contingent considerations
      -
      -
      (13,936 )

    Adjustment for changes in fair value of derivative instrument
      -
      -
      (3,696 )

    Adjusted net loss from continuing operations attributable to BIT Mining Limited (non-GAAP)
      (16,957 )
      (11,021 )
      (21,331 )

    Net income (loss) from discontinued operations
      (20,009 )
      (8,779 )
      (8,921 )

    Less: Net (loss) income from
                                            discontinued operations attributable to noncontrolling interest

      (438 )
      309
      (179 )

    Net loss from discontinued operations attributable to BIT Mining Limited

      (19,571 )
      (9,088 )
      (8,742 )

    Adjust for discontinued operations:

    Adjustment for impairment of long-term investments
      1,869
      -
      -

    Adjustment for deferred tax benefit relating to valuation allowance
      (26 )
      -
      -

    Adjusted net loss from discontinued operations attributable to BIT Mining Limited (non-GAAP)
      (17,728 )
      (9,088 )
      (8,742 )

Simpson Thacher & Bartlett

September 6, 2022 -6- Division of Corporation

United States securities and exchange commission logo
August 22, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Ltd
Units 813 &815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 7, 2022
File No. 001-36206
Dear Mr. Yang:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31 ,2021
Conventions that Apply to this Annual Report on Form 20-F, page 1
1.Please revise to your definition of "China" and the "PRC" to remove the exclusion of
Taiwan, Hong Kong and Macau.
Item 3. Key Information , page 3
2.At the onset of Part I, please disclose that you use a holding company structure and what
that entails.  Provide here a summary diagram of the company's corporate structure,
identifying the person or entity that owns the equity in each depicted entity.  Clearly
identify the entity in which investors hold an interest and the entities in which the
company conducts it operations and clarify whether you conduct your current operations
through any variable interest entities.  Also, revise Part I to disclose, if true, that you do
not have revenue-generating operations in China.  Disclose that adverse actions by the

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 22, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
August 22, 2022
Page 2
Chinese government may force you to cease your administrative support and internal
information technology services from China to your international cryptocurrency mining
business.  Clarify that you have developed Ethereum mining operations in Hong Kong and
whether you have plans to further expand your Hong Kong-based operations.  Lastly,
disclose here the amount of revenue from your Hong Kong operations for each period
presented.
3.At the onset of Part I, please provide a clear description of how cash is transferred through
your organization and disclose your intentions to distribute earnings. State whether any
transfers, dividends, or distributions have been made to date between the holding
company and its subsidiaries, or to investors, and quantify the amounts where applicable
and the direction of transfer.  Quantify any dividends or distributions that a subsidiary has
made to the holding company, which entity made such transfer, and their tax
consequences, if any.  Similarly quantify dividends or distributions made to U.S.
investors, the source, and their tax consequences. Your disclosure here should make clear
if no transfers, dividends, or distributions have been made to date.  Also, describe in the
forepart of Part I any restrictions on foreign exchange and your ability to transfer cash
between entities, across borders, and to U.S. investors. Describe any restrictions and
limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors.
4.Please revise the forepart of Part I to address each of the legal and operational risks
associated with conducting your business in Hong Kong set forth in the sample letter to
China-based companies available on our website. We refer you to your response to
comment 1 in your May 6, 2022 letter. Also, ensure that your disclosures address whether
your auditor is subject to the determinations announced by the PCAOB on December 16,
2021 and whether and how the Holding Foreign Companies Accountable Act (HFCAA)
and the Accelerating HFCAA and related regulations will affect your company.
Risk Factors
Because there has been limited precedent set for financial accounting of bitcoin and other
cryptocurrency assets..., page 29
5.You state that "there has been limited precedent set for the financial accounting of
cryptocurrencies and related revenue recognition and no official guidance has yet been
provided by the FASB or the SEC, [such that] it is unclear how companies may in the
future be required to account for cryptocurrency transactions and assets and related
revenue recognition.”  Please help us understand the basis for these statements and your
accounting policies, and consider the need to revise or remove these statements.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 22, 2022 Page 3
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
August 22, 2022
Page 3
You will have limited ability to bring an action against us or against out directors....., page 40
6.You state here that you conduct operations exclusively in China.  Please reconcile this
statement with your disclosures elsewhere throughout the filing where you refer to limited
operations in China that relate mainly to providing administrative support to your
cryptocurrency mining business outside the PRC.  Please explain or revise.
Item 5. Operating and Financial Review and Prospects
A. Operating Results, page 62
7.Please tell us why you believe that adjusting for the impairment of cryptocurrencies and
the net gain on disposal of cryptocurrencies provides useful information to investors
considering the nature of your business, your strategy to hold bitcoin as an investment and
sell bitcoin in future periods as needed for cash flow needs, and the recurring nature of
these charges. Please explain or revise to remove these adjustments from your
computation of non-GAAP adjusted net loss.  Refer to Rule 100 of Regulation G.
8.Please revise to include the income tax effects as a separate adjustment and expand your
disclosure to clearly explain how the tax effects of the non-GAAP adjustments are
calculated, or explain why you do not believe this is necessary.  Refer to Question 102.11
of the Non-GAAP C&DIs.
9.We note you present non-GAAP measures of adjusted net loss from continuing operations
attributable to Bit Mining and adjusted net income from discontinued operations
attributable to Bit Mining.  Please revise to include a reconciliation for each of these non-
GAAP measures.  Refer to Item 10(e)(1)(i)(B) of Regulation S-K.
10.Please enhance your disclosures in footnote (1) on page 64 to more clearly explain why
management believes your non-GAAP measures are useful to investors and how they help
investors compare your business trends.  Also, to the extent material, disclose the
additional purposes, if any, for which management uses each of these non-GAAP
measure.  Refer to Item 10(e)(1)(i)(C) and (D) of Regulation S-K.
The year ended December 31, 2021 compared with the year ended December 31, 2020, page 64
11.Please revise to discuss the reasons for the negative profit margins in your mining pool
segment as disclosed in Note 24 and explain whether you anticipate this trend to continue
in future periods.  In your response, tell us the amount paid to the mining pool participants
that is included in cost of revenue for each period.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 22, 2022 Page 4
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
August 22, 2022
Page 4
E. Critical Accounting Estimates, page 71
12.Considering the significance of your mining operations, please tell us how you considered
including a discussion here of the significant estimates, assumptions and uncertainty
associated with the revenue recognition policies related to your cryptocurrency mining
and mining pool services operations as well as your accounting for cryptocurrency assets,
or revise as necessary. Refer to Item 5.E of Form 20-F.
Item 8. Financial Information
Note 2. Summary of Significant Accounting Policies, page F-15
13.It appears from the supplemental disclosures in your cash flow statement that you have
paid expenses and acquired non-current assets in exchange for cryptocurrency. Please
revise to include your accounting policy related to nonmonetary transactions.
Cryptocurrency Assets, page F-18
14.You state for purposes of testing cryptocurrency assets for impairment the fair value is the
the quoted price at "the time its fair value is being measured.”  Please explain further at
what point fair value is measured.  In this regard, clarify whether you assess fair value
throughout each day, at a point in time during the day or reporting period, or something
else.  Also, tell us and revise your policy to clarify whether you recognize an impairment
whenever the carrying value for your cryptocurrency assets is below the fair value for
each unit of account.  We refer you to ASC 350-30-35-19.  Lastly, provide us with a
breakdown by type of the cryptocurrency assets held at each balance sheet date and tell us
the source used to determine the fair value for each type.
Revenue Recognition
Cryptocurrency Mining, page F-23
15.You state that the Group's enforceable right to compensation only begins when the Group
provides computing power to the mining pool operator.  Please clarify for what period
each party to your contract has enforceable rights and obligations and the basis for your
conclusion.  In your response, explain whether your right or the pool operator’s right to
terminate the contract governing your participation in the pool is conditional. Please also
summarize the material rights and obligations of each party to your pool participation
contracts including:
•Whether you have the right under your contract with the pool operator to decide at
what point in time and for what duration you will provide computing power,
including whether you can start and stop providing computing power then resume
providing it; whether you are required to start providing it at a specific time;
•How your evaluation of contract inception and contract duration considered your
rights, if any, to determine when to commence and cease providing computing power.
•How the amount of rewards received for providing computing power may be
impacted should you start and stop mining within the contract period.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 22, 2022 Page 5
 FirstName LastNameXianfeng Yang
BIT Mining Ltd
August 22, 2022
Page 5
16.You state the provision of providing computing power is the only performance obligation
in your contracts with the mining pool operator.  Please tell us whether you satisfy your
performance obligation over time or at a point in time and how you considered the
guidance in ASC 606-10-25-24.
17.Please clarify whether you are  entitled to a fractional share of the cryptocurrency award
that the mining pool operator receives only if a block is successfully added to the
blockchain as your disclosures suggest, or whether you are entitled to compensation
regardless of whether the pool operator successfully records a block. In this regard, we
note references to settlement terms under the FPPS model on the website for at least one
of your mining pool operators, BTC.com. If you provide power to more than one pool
operator, ensure that your disclosures address the terms for each type of arrangement to
the extent they differ.  Also, tell us whether you separately receive the proportional share
of transaction fees earned by the pool operator and if so, how you account for such fees.
18.You state that the consideration you receive is noncash consideration, which you measure
at fair value on the date earned. Please tell us how this complies with the guidance ASC
606-10-32-21 to 32-24 to measure fair value of noncash consideration at contract
inception.  Provide an analysis to support your assertion that the fair value on the date
earned is not materially different than the fair value at contract inception or the time you
have earned the award from the pools.  Also, tell us at what is meant by "earned" in this
statement and clarify the time periods between successful placement of a block on the
blockchain by the pool operator, receipt of confirmation, and receipt of consideration.
19.Please describe the approximate time interval for each blockchain between successful
block placements.
Mining Pool Services, page F-24
20.Please clarify whether "gross revenue" related to your mining pool services includes the
pool fees earned as the pool operator with third party miners.  Also, describe the nature of
the amounts included in cost of revenue related to your mining pool services.
21.Please clarify the time periods between successful placement of a block on the blockchain
and receipt of consideration for each type of crytocurrency asset mined.  Also, provide an
analysis to support your assertion that the fair value of rewards upon receipt is not
materially different then the fair value at contract inception.
Note 19. Related Party Transactions, page F-56
22.We note from footnote (1) on page 79 that Mr. Man San Vincent Law, the company's
founder and executive director has beneficial ownership in 85.5 million Class A ordinary
shares via his ownership interest in Good Luck Capital Limited.  We further note that
Good Luck Capital obtained such shares through a share subscription agreement with the
company in December 2020.  Please explain why you have not identified this agreement
as a related party transaction or revise as necessary.  Refer to ASC 850-50.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Ltd
 August 22, 2022 Page 6
 FirstName LastName
Xianfeng Yang
BIT Mining Ltd
August 22, 2022
Page 6
Note 24. Segment Reporting, page F-63
23.Please revise to provide the disclosures required by ASC 280-10-50-41.
            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.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
filename1.htm

BIT
Mining Limited

Units 813&815, Level 8, Core F, Cyberport
3

100 Cyberport Road

Hong Kong

+852 5987-5938

May
13, 2022

VIA EDGAR

Division of Corporation
Finance

Office of Technology

Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Mr. Larry Spirgel

    Ms. Jan Woo

    Mr. Jeff Kauten

    Re:
    BIT Mining Limited (CIK No. 0001517496)

    Registration Statement on Form F-3 (File No. 333-258329)

Dear Mr. Larry Spirgel,
Ms. Jan Woo and Mr. Jeff Kauten:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), BIT Mining Limited (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-3 (the “Registration Statement”)
of the Company be accelerated by the Securities and Exchange Commission (the “Commission”) to, and that the Registration Statement
become effective at 4:00 P.M., Eastern Time, on May 17, 2022, or as soon thereafter as practicable.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461 under
the Securities Act. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel,
Wilson Sonsini Goodrich & Rosati.

The Company hereby acknowledges
the following:

    •
    should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    •
    the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •
    the Company may not assert the Staff’s comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Signature
page follows]

    Very truly yours,

    BIT Mining Limited

    By:
    /s/ Bo Yu

    Name:
    Bo Yu

    Title:
    Chairman of the Board and Chief Operating Officer

    -2-

CORRESP
1
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    Suite
    1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址:
    www.wsgr.com

Confidential May 6, 2022

Mr. Larry Spirgel

Ms. Jan Woo

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: BIT Mining Limited (CIK No. 0001517496)

Response to the Staff’s
Comments on

Amendment No.9
to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on April 19, 2022

Dear
Mr. Larry Spirgel, Ms. Jan Woo and Mr. Jeff Kauten,

On behalf of our client, BIT
Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated May 3, 2022 on the
Company’s Amendment No.9 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on April
19, 2022 (the “Amendment No.9”). Concurrently with the submission of this letter, the Company is filing with the Commission
Amendment No.10 to the Registration Statement (the “Amendment No.10”) and certain exhibits via EDGAR for Staff’s
review.

The Staff’s
comments are repeated below in bold and are followed by the Company’s responses. We have included page references in the
Amendment No.10 where the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined
herein have the meanings set forth in the Amendment No.10. To facilitate your review, we have separately emailed you a courtesy copy
of the Amendment No.10, marked to show changes to the Amendment No.9, and the submitted exhibits. We would highly appreciate your
prompt review of this Amendment No.10 and are looking forward to a closure of this prolonged review process.

Cover Page

 1. We note your response to prior comment 1 and your references to mainland China throughout the filing.
As you conduct a significant portion of your operations in Hong Kong, please revise your disclosure throughout the filing to address each
of the legal and operational risks associated with conducting your business in Hong Kong set forth in the sample letter
to China-based companies available on our website.

The Company respectfully
advises the Staff that its operation in Hong Kong primarily involves mining Ethereum, and it does not plan to further expand such
Hong Kong-based operation. In 2021, the Company’s operations in Hong Kong generated approximately 1.4% of its total revenue
for such year. The Company has revised disclosure throughout the filing, where appropriate, to disclose the impact of legal and
operational risks associated with its operations in Hong Kong, including a risk factor relating to its Hong Kong subsidiaries being
subject to more influence and/or control of the PRC government on page 22 of the Amendment No. 10.

Wilson
Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners
 合夥人: Weiheng Chen 陳煒恒,
Dan Ouyang 歐陽丹*, Winfield Lau 劉泳暉

*Not Resident
in Hong Kong

austin
beijing     boston     brussels hong kong     london     los angeles     new york palo alto

san diego     san francisco     seattle     shanghai     washington, dc     wilmington, de

 2. Please disclose the percentage of your revenues derived from
Hong Kong and Macau for the periods presented and include corresponding disclosure in the prospectus summary.

The
Company respectfully advises the Staff that it does not have any operation in Macau. The Company has revised the disclosure on
the cover page and page 4 of the Amendment No.10 to include the percentage of its revenue derived from the Company’s operations
in Hong Kong.

 3. We note your disclosure that you do not have any variable interest entities in China.  Please
disclose whether you have any variable interest entities in Macau or Hong Kong.

The
Company respectfully advises the Staff that it does not have any variable interest entities in Hong Kong or Macau. Please refer
to revised disclosure on the cover page and page 4 of the Amendment No.10.

 4. We note your disclosure that you no longer have any revenue-generating operations in mainland
China.  Please disclose that adverse actions by the Chinese government may force you to cease your administrative support
and internal information technology services from China to your international cryptocurrency mining business.

In response to the Staff’s
comment, the Company has updated the disclosure on the cover page and pages 12 and 22 of the Amendment No.10.

***

If you have any questions regarding the Amendment
No. 10 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
May 3, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 9 to Registration Statement on Form F-3
Filed April 19, 2022
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our April 18, 2022 letter.
Amendment No. 9 to Registration Statement on Form F-3
Cover Page
1.We note your response to prior comment 1 and your references to mainland China
throughout the filing.  As you conduct a significant portion of your operations in Hong
Kong, please revise your disclosure throughout the filing to address each of the legal and
operational risks associated with conducting your business in Hong Kong set forth in the
sample letter to China-based companies available on our website.
2.Please disclose the percentage of your revenues derived from Hong Kong and Macau for
the periods presented and include corresponding disclosure in the prospectus summary.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 May 3, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
May 3, 2022
Page 2
Our Company
Our Business, page 4
3.We note your disclosure that you do not have any variable interest entities in China.
Please disclose whether you have any variable interest entities in Macau or Hong Kong.
4.We note your disclosure that you no longer have any revenue-generating operations in
mainland China.  Please disclose that adverse actions by the Chinese government may
force you to cease your administrative support and internal information technology
services from China to your international cryptocurrency mining business.
            You may contact Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香 港 中 環

    康
    樂 廣 場 一 號

    怡
    和 大 廈 15 樓

    1509 室

    電
    話: 852-3972-4955

    傳
    真: 852-3972-4999

    網
    址: www.wsgr.com

    Confidential
     April 19, 2022

Mr. Larry Spirgel

Ms. Jan Woo

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: BIT Mining Limited (CIK No. 0001517496)

Response to the Staff’s
Comments on

Amendment No.8
to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on April 8, 2022

Dear Mr.
Larry Spirgel, Ms. Jan Woo and Mr. Jeff Kauten,

On behalf of our client,
BIT Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”),
we are hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) this letter setting forth the Company’s responses to the comments contained in the
Staff’s letter dated April 18, 2022 on the Company’s Amendment No.8 to the Registration Statement on Form F-3
(Registration No. 333-258329) filed with the Commission on April 8, 2022 (the “Amendment No.8”). Concurrently
with the submission of this letter, the Company is filing with the Commission Amendment No.9  to the Registration Statement (the
“Amendment No.9”) and certain exhibits via EDGAR for Staff’s review.

The Staff’s
comments are repeated below in bold and are followed by the Company’s responses. We have included page references in the
Amendment No.9 where the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Amendment No.9. To facilitate your review, we have separately emailed you a courtesy copy of the
Amendment No.9, marked to show changes to the Amendment No.8. We would highly appreciate
your prompt review of this Amendment No.9 and are looking forward to a favorable closure of this review process.

Cover Page

 1. Please revise your disclosure that you do not have revenue-generating operations in China to clarify
that you have been growing your operations in Hong Kong and that you have cryptocurrency mining data centers in Hong Kong. Also,
revise your disclosure on page 1 to remove the exclusion of Taiwan, Hong Kong and Macau from the definition of the PRC and China.

The
Company respectfully submits that it has developed Ethereum mining operation in Hong Kong but has no plan to further expand such Hong
Kong-based operation. This is because the Company is focusing on growing its cryptocurrency mining operations in the United States. In
response to the Staff’s comment, the Company has revised the disclosure on the cover page and page 1 of the Amendment No.9 and made
corresponding updates in the relevant disclosure in respect of the definition of the PRC and China.

***

    Wilson Sonsini Goodrich & Rosati

威 爾 遜 • 桑 西 尼 • 古 奇 • 羅 沙 迪 律 師 事 務 所

Partners 合 夥 人: Weiheng Chen 陳 煒 恒, Dan Ouyang 歐 陽 丹*, Winfield Lau 劉 泳 暉

*Not Resident in Hong Kong

austin      beijing      boston      brussels      hong kong      london      los angeles      new york      palo alto
 san diego      san francisco      seattle      shanghai      washington, dc      wilmington, de

If you have any questions regarding the Amendment
No. 9 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
April 18, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 8 to Registration Statement on Form F-3
Filed April 8, 2022
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 8 to Registration Statement on Form S-3
Cover Page
1.Please revise your disclosure that you do not have revenue-generating operations in China
to clarify that you have been growing your operations in Hong Kong and that you have
cryptocurrency mining data centers in Hong Kong.  Also, revise your disclosure on page 1
to remove the exclusion of Taiwan, Hong Kong and Macau from the definition of the PRC
and China.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 April 18, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
April 18, 2022
Page 2
            You may contact Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

Suite
                                         1509

15/F Jardine House

1 Connaught Place

Central, Hong Kong

Phone: 852-3972-4955

Fax: 852-3972-4999

Website: www.wsgr.com

 香港中環

康樂廣場一號

怡和大廈15樓

1509室

電話:
852-3972-4955

傳真:
852-3972-4999

網址: www.wsgr.com

  Confidential
  April 8, 2022

Mr. Jeff Kauten

Mr. Josh Shainess

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  BIT Mining Limited (CIK No. 0001517496)

Response to the Staff’s
Comments on

Amendment No.7
to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on January 25, 2022

Dear Mr. Kauten and Mr. Shainess,

On behalf of our client,
BIT Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we
are hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated March 30, 2022 on
the Company’s Amendment No.7 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission
on January 25, 2022 (the “Amendment No.7”). Concurrently with the submission of this letter, the Company is filing
with the Commission Amendment No.7 to the Registration Statement (the “Amendment No.8”) and certain exhibits via EDGAR
for Staff’s review.

The Staff’s
comments are repeated below in bold and are followed by the Company’s responses. We have included page references in the
Amendment No.8 where the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Amendment No.8. To facilitate your review, we have separately sent to you today an electronic
courtesy copy of the Amendment No.8, marked to show changes to the Amendment No.7, and two copies of the submitted exhibits. We
highly appreciate your prompt review of this Amendment No.8 and look forward to a favorable conclusion.

Cover Page

 1. Clearly disclose how you will refer
                                            to the holding company and subsidiaries when providing the disclosure throughout
                                            the document so that it is clear to investors which entity the disclosure is referencing
                                            and which subsidiaries or entities are conducting the business operations. Disclose clearly
                                            the entity (including the domicile) in which investors are purchasing an interest.

The Company respectfully submits
that the Company does not maintain any variable interest entity structure in China and does not have any consolidated affiliated
entities in China that the Company controls through contractual arrangements. As used in the
Amendment No.8, “we,” “us,” “our company,” “the Company” or “our”
refers to BIT Mining Limited, a Cayman Islands company and its subsidiaries in Hong Kong, British Virgin Islands, Canada, Malta,
Cyprus, Curacao, Kazakhstan, the United States and China. In response to the Staff’s
comment, the Company has updated the disclosure on the cover page and page 4 of the Amendment No.8.

Wilson Sonsini
Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners
 合夥人: Weiheng Chen 陳煒恒,
Dan Ouyang 歐陽丹*, Winfield Lau 劉泳暉

*Not Resident
in Hong Kong

austin      beijing      boston      brussels      hong kong      london      los angeles      new york      palo alto

san diego      san francisco      seattle      shanghai      washington, dc      wilmington, de

 2. Please disclose whether
                                            you have cash management policies and procedures that dictate how funds are transferred,
                                            and if so, describe these policies and procedures.  Please include corresponding disclosure
                                            in the prospectus summary.

The Company respectfully submits that
the Company does not have a written policy or procedure that specifically dictates how funds are transferred among entities. However,
to the extent that the Company transfers fund to subsidiaries in China, it has required (1) that its PRC subsidiaries have completed
the registration with the local branch of the State Administration of Foreign Exchange to clear the PRC foreign exchange controls; and
(2) that any loan or capital injection to its PRC subsidiaries be made and used on an ad-hoc basis. In response to the Staff’s
comment, the Company has updated the disclosure on page 8  of the Amendment No.8.

 3. Disclose clearly that the company
                                            uses a holding company structure and what that entails, and provide early in the summary
                                            a diagram of the company’s corporate structure, identifying the person or entity that
                                            owns the equity in each depicted entity.  Identify clearly the entity in which investors
                                            are purchasing their interest and the entity(ies) in which the company’s operations
                                            are conducted.

In response to the Staff’s comment,
the Company has updated the disclosure on page 7 of the Amendment No.8.

 4. We note your statement that
                                            you believe you have obtained the business licenses and permits required for your remaining
                                            non-revenue generating operations in the PRC.  Please disclose each permission or approval
                                            that you or your subsidiaries are required to obtain from Chinese authorities to
                                            operate your business and to offer the securities being registered to foreign investors.  Please
                                            also describe the consequences to you and your investors if you or your subsidiaries:
                                            (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude
                                            that such permissions or approvals are not required, or (iii) applicable laws, regulations,
                                            or interpretations change and you are required to obtain such permissions or approvals in
                                            the future.

In response to the Staff’s comment,
the Company has updated the disclosure on page 9 of the Amendment No.8.

Our Risks and Challenges, page 7

 5. For each risk applicable to
                                            China-based companies, please provide a cross-reference to the section of the risk factors
                                            related to being a China-based issuer.

In response to the Staff’s comment,
the Company has updated the disclosure on pages 11 to 13 of the Amendment No.8.

Risk Factors, page 11

 6. We note that one or more of
                                            your officers or directors are located in China.  Please revise to include risk factor
                                            disclosure to address the difficulty of bringing actions against these individuals and enforcing
                                            judgments against them and include a cross-reference to the enforcement of civil liabilities section.

In response to the Staff’s comment,
the Company has updated the disclosure on pages 12 and 23 of the Amendment No.8.

Our ADSs could still be
delisted from a U.S. exchange..., page 18

 7. Please update your disclosure
                                            to reflect that, pursuant to the HFCAA, the PCAOB has issued its report notifying the Commission
                                            of its determination that it is unable to inspect or investigate completely accounting firms
                                            headquartered in mainland China or Hong Kong

In response to the Staff’s comment,
the Company has updated the disclosure on pages 11, 20 and 21 of the Amendment No.8.

***

If you have any questions
regarding the Amendment No. 8 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
March 30, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 7 to Registration Statement on Form F-3
Filed January 25, 2022
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.
Amendment No. 7 to Registration Statement on Form S-3
Cover Page
1.Clearly disclose how you will refer to the holding company and subsidiaries when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations. Disclose clearly the entity (including the domicile) in which investors
are purchasing an interest.
2.Please disclose whether you have cash management policies and procedures that dictate
how funds are transferred, and if so, describe these policies and procedures.  Please
include corresponding disclosure in the prospectus summary.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 March 30, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
March 30, 2022
Page 2
Our Company, page 5
3.Disclose clearly that the company uses a holding company structure and what that entails,
and provide early in the summary a diagram of the company’s corporate structure,
identifying the person or entity that owns the equity in each depicted entity.  Identify
clearly the entity in which investors are purchasing their interest and the entity(ies) in
which the company’s operations are conducted.
4.We note your statement that you believe you have obtained the business licenses and
permits required for your remaining non-revenue generating operations in the PRC.
Please disclose each permission or approval that you or your subsidiaries are required to
obtain from Chinese authorities to operate your business and to offer the securities being
registered to foreign investors.  Please also describe the consequences to you and your
investors if you or your subsidiaries: (i) do not receive or maintain such permissions or
approvals, (ii) inadvertently conclude that such permissions or approvals are not required,
or (iii) applicable laws, regulations, or interpretations change and you are required to
obtain such permissions or approvals in the future.
Our Risks and Challenges, page 7
5.For each risk applicable to China-based companies, please provide a cross-reference to the
section of the risk factors related to being a China-based issuer.
Risk Factors, page 11
6.We note that one or more of your officers or directors are located in China.  Please revise
to include risk factor disclosure to address the difficulty of bringing actions against these
individuals and enforcing judgments against them and include a cross-reference to the
enforcement of civil liabilities section.
Our ADSs could still be delisted from a U.S. exchange..., page 18
7.Please update your disclosure to reflect that, pursuant to the HFCAA, the PCAOB has
issued its report notifying the Commission of its determination that it is unable to inspect
or investigate completely accounting firms headquartered in mainland China or Hong
Kong.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 March 30, 2022 Page 3
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
March 30, 2022
Page 3
            You may contact Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Josh
Shainess, Legal Branch Chief, at (202) 551-7951, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址:
    www.wsgr.com

    Confidential
    January 25, 2022

Ms. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:         BIT Mining Limited
(CIK No. 0001517496)

Response to the Staff’s
Comments on

Amendment No.6
to the Registration Statement on Form F-3 (Registration No. 333-258329)

Filed on January
7, 2022

Dear Ms. Barone and Mr. Kauten,

On behalf of our client, BIT
Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated January 20, 2022 on
the Company’s Amendment No.6 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on
January 7, 2022 (the “Amendment No.6”). Concurrently with the submission of this letter, the Company is filing with
the Commission the Amendment No.7 to the Registration Statement (the “Amendment No.7”) and certain exhibits via EDGAR
for Staff’s review.

The Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the Amendment No.7 where
the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set
forth in the Amendment No.7. To facilitate your review, we have separately delivered to you today five courtesy copies of the Amendment
No.7, marked to show changes to the Amendment No.6, and two copies of the submitted exhibits. We appreciate your prompt review of this
Amendment no.7.

Our Company, page 5

 1. We note your response to prior comment 2 and your statement that, other than Bitcoin, Ethereum
and Dogecoin, you do not mine or hold any other type of cryptocurrencies that represents greater than 1% of the Company’s
total assets as of September 30, 2021.  Please disclose a complete list of all mined digital assets and identify each specific
digital asset, other than Bitcoin, Ethereum, and Dogecoin, that you hold that represents greater than 1% of your total assets, in each
case as of the date of the prospectus.

The Company respectfully advises
the Staff that its cryptocurrency mining business focuses on mining Bitcoin and Ethereum, and the Company receives various other types
of digital assets, primarily consisting of Bitcoin, Ethereum and Dogecoin, as commissions from its mining pool operation. As of the date
hereof, the Company holds Bitcoin, Ethereum and Dogecoin, which are the only digital assets each accounts for more than 1.0% of the Company’s
total assets (unaudited) as of December 31, 2021. These three specific digital assets in the aggregate account for less than 12.0% of
the Company’s total assets (unaudited) as of December 31, 2021. The other digital assets the Company holds as of the date hereof
collectively represent less than 2.0% of the Company’s total assets (unaudited) as of December 31, 2021, with no single digital
asset (excluding Bitcoin, Ethereum and Dogecoin) held as of the date hereof individually representing more than 1.0% of the Company’s
total assets (unaudited) as of December 31, 2021. Therefore, the Company believes that a complete list of digital asset holdings does
not present material information for the Company’s digital assets portfolio or its cryptocurrency mining operation. The Company
respectfully requests not to disclose a complete list of digital asset holdings in the Amendment No.7, other than Bitcoin, Ethereum and
Dogecoin, which as of the date hereof individually accounts for more than 1.0% of the Company’s total assets (unaudited) as of December
31, 2021.

The Company further respectfully
advises the Staff that the Company regularly compiles its management account at the end of fiscal quarter, and therefore, is unable to
provide its total assets as of the date of the prospectus without incurring substantial costs. The Company respectfully requests to use
its total assets (unaudited) as of December 31, 2021 as the denominator to calculate the breakdown of digital assets individually representing
greater than 1.0% of the value of its total assets. The Company further confirms that as of the date hereof, other than Bitcoin, Ethereum
and Dogecoin, the Company does not hold any other type of cryptocurrencies that individually represents greater than 1.0% of the value
of its total assets (unaudited) as of December 31, 2021.

In response to the Staff’s
comment, the Company has updated the disclosure on page 6 of the Amendment No.7.

Rule 418 and Rule 12b-4
Request

Pursuant
to Rule 418 promulgated under the Securities Act of 1933, as amended, and Rule 12b-4 promulgated under the Securities Exchange Act of
1934, as amended, we are providing certain additional information to the Staff on a supplemental basis only (the “Supplemental
Information”) and is not to be filed with or deemed part of the Amendment No. 7.

Pursuant
to Rule 418(b) and Rule 12b-4, we hereby request on behalf of the Company that the Supplemental Information be returned to the undersigned
or destroyed promptly following completion of the Staff’s review of the Supplemental Information.

***

If you have any questions regarding the Amendment
No. 7 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
January 20, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 6 to Registration Statement on Form F-3
Filed January 7, 2022
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 3, 2022 letter.
Amendment No. 6 to Registration Statement on Form F-3
Our Company, page 5
1.We note your response to prior comment 2 and your statement that, other than Bitcoin,
Ethereum and Dogecoin, you do not mine or hold any other type of cryptocurrencies that
represents greater than 1% of the Company’s total assets as of September 30, 2021.
Please disclose a complete list of all mined digital assets and identify each specific digital
asset, other than Bitcoin, Ethereum, and Dogecoin, that you hold that represents greater
than 1% of your total assets, in each case as of the date of the prospectus.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 January 20, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
January 20, 2022
Page 2
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten, Staff
Attorney, at (202) 551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

Confidential January 7, 2022

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: BIT Mining Limited (CIK No. 0001517496)

                                                                                Response to the Staff’s Comments on

                                                                                Amendment No.5
to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on December 20, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT
Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated January 3, 2022 on
the Company’s Amendment No.5 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on
December 20, 2021 (the “Amendment No.5”). Concurrently with the submission of this letter, the Company is filing with
the Commission Amendment No.6 to the Registration Statement (the “Amendment No.6”) and certain exhibits via EDGAR for
Staff’s review.

As per the updated disclosure
in the Amendment No.6, we respectfully submit for your attention that the Company has completed the migration of its crypto mining business
to non-PRC jurisdictions and no longer has any PRC-sourced revenue. In addition, our U.S.-based auditor MaloneBailey, LLP is not among
the PCAOB-registered public accounting firms headquartered in the PRC or Hong Kong that are subject to PCAOB’s determination of
having been unable to inspect or investigate completely.

The Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the Amendment No.6 where
the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set
forth in the Amendment No.6. To facilitate your review, we have separately delivered to you today five courtesy copies of the Amendment
No.6, marked to show changes to the Amendment No.5, and two copies of the submitted exhibits. As mentioned during our prior communications
with the Staff, since September 2021, the Company has been subject to contractual penalties under its investment agreement dated July
12, 2021 with certain investors as a result of this registration statement on form F-3 having not been declared effective. We are aware
of the unconventional circumstances since the end of July 2021, but would very much appreciate the Staff’s prompt review of this
amendment filing and decision thereupon.

Cover Page

 1. Please disclose whether your auditor is subject to the determinations announced by the PCAOB on December
16, 2021 and whether and how the Holding Foreign Companies Accountable Act and related regulations will affect your company.

The Company respectfully advises the
Staff that the auditor of the Company, MaloneBailey, LLP, is not among the PCAOB-registered
public accounting firms headquartered in the PRC or Hong Kong that are subject to PCAOB’s
determination on December 16, 2021 of having been unable to inspect or investigate completely. MaloneBailey, LLP is headquartered in the
United States with offices in Beijing and Shenzhen. However, the audit working papers of the Company’s financial statements
may not be fully inspected by the PCAOB without the approval of the PRC authorities, since the prior audit work was carried out by MaloneBailey,
LLP with the collaboration of its China-based offices. As disclosed on the cover page and pages 7, 18 and 19 of the Amendment No.
6, the Company’s ADSs could still be delisted from a U.S. exchange and prohibited from being traded over-the-counter in
the United States under the Holding Foreign Companies Accountable Act if the PCAOB determines in the future that it is unable to fully
inspect or investigate our auditor which has a presence in China.

Our Company, page 5

 2. We note your response to prior comment 2 and your disclosure that you acquire other types of cryptocurrencies,
including Dogecoin, as commission of your mining pool operation. Please expand your disclosure to identify each specific digital asset,
other than Bitcoin, Ethereum, and Dogecoin, that you mine or hold that represents greater than 1% of your total assets. Also, expand your
disclosure regarding your data center operation to host cryptocurrency mining activities and your multi-currency comprehensive
service mining pool to include a discussion as to how these two business lines operate, which digital assets are mined and supported and
the compensation structure.

The Company respectfully advises the
Staff that, other than Bitcoin, Ethereum and Dogecoin, the Company does not mine or hold any other type of cryptocurrencies that represents
greater than 1% of the Company’s total assets as of September 30, 2021.

In response to the Staff’s comment,
the Company has revised and expanded the disclosure on pages 5 and 6 of the Amendment No.6.

Our Digital Assets, page 6

 3. Please clarify whether you settle block reward distribution with your customers in fiat currency
or digital assets.

The Company respectfully advises the
Staff that it settles mining rewards, which consist of block rewards and transaction verification fees, in the respective cryptocurrencies
mined in each transaction under the mining pool policies. In response to the Staff’s comment, the Company has clarified the disclosure
on page  6 of the Amendment No.6.

Risk Factors

The loss or destruction of private keys..., page 14

 4. We note your response to prior comment 3.  Please provide a more detailed explanation of your enterprise multi-signature
storage solution and the specific risks associated with this storage solution.

In response to the Staff’s comment,
the Company has updated the disclosure on pages  6 and 14 of the Amendment No.6.

Our ADSs may be delisted from a U.S. exchange..., page 18

 5. Please update your disclosure to reflect that the PCAOB has issued its report notifying the Commission of its determination that
it is unable to inspect or investigate completely accounting firms headquartered in mainland China or Hong Kong.

In response to the Staff’s comment,
the Company has updated the disclosure on pages 18 and 19 of the Amendment No.6.

***

If you have any questions regarding the Amendment
No. 6 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
January 3, 2022
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 5 to Registration Statement on Form F-3
Filed December 20, 2021
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our December 16, 2021 letter.
Amendment No. 5 to Registration Statement on Form F-3
Cover Page
1.Please disclose whether your auditor is subject to the determinations announced by the
PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies
Accountable Act and related regulations will affect your company.
Our Company, page 5
2.We note your response to prior comment 2 and your disclosure that you acquire other
types of cryptocurrencies, including Dogecoin, as commission of your mining pool
operation. Please expand your disclosure to identify each specific digital asset, other than

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 January 3, 2022 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
January 3, 2022
Page 2
Bitcoin, Ethereum, and Dogecoin, that you mine or hold that represents greater than 1% of
your total assets. Also, expand your disclosure regarding your data center operation to
host cryptocurrency mining activities and your multi-currency comprehensive service
mining pool to include a discussion as to how these two business lines operate, which
digital assets are mined and supported and the compensation structure.
Our Digital Assets, page 6
3.Please clarify whether you settle block reward distribution with your customers in fiat
currency or digital assets.
Risk Factors
The loss or destruction of private keys..., page 14
4.We note your response to prior comment 3.  Please provide a more detailed explanation of
your enterprise multi-signature storage solution and the specific risks associated with this
storage solution.
Our ADSs may be delisted from a U.S. exchange..., page 18
5.Please update your disclosure to reflect that the PCAOB has issued its report notifying the
Commission of its determination that it is unable to inspect or investigate completely
accounting firms headquartered in mainland China or Hong Kong.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten,
Staff Attorney, at (202) 551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址:
    www.wsgr.com

Confidential

  December 20, 2021

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: BIT Mining Limited (CIK No. 0001517496)

                                                                                Response to the Staff’s Comments on

                                                                                Amendment No.4 to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on December 9, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT
Mining Limited, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
hereby submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated December 16, 2021
on the Company’s Amendment No.4 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission
on December 9, 2021 (the “Amendment No.4”). Concurrently with the submission of this letter, the Company is filing
with the Commission Amendment No.5 to the Registration Statement (the “Amendment No.5”) and certain exhibits via EDGAR
for Staff’s review.

As per the updated disclosure
in the Amendment No. 5, we respectfully submit for your attention that the Company has migrated its crypto mining business to non-PRC
jurisdictions and no longer has any revenue-generating operation in the PRC.

The Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the Amendment No.5 where
the disclosure addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set
forth in the Amendment No.5. To facilitate your review, we have separately delivered to you today five courtesy copies of the Amendment
No.5, marked to show changes to the Amendment No.4, and two copies of the submitted exhibits.

Our Company, page 5

 1. We note your disclosure that you primarily mine Bitcoin and Ethereum cryptocurrencies and that you
hold digital assets which primarily consist of Bitcoin, Ethereum and Dogecoin. Provide a detailed description of the process and framework
that you will use to determine whether any digital assets that you may hold or acquire are securities as defined in Section 2(a)(1) of
the Securities Act of 1933.

In response to the Staff’s
comment, the Company has revised the disclosure on pages 6, 13 and 14 of the Amendment No.5.

Wilson
Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners 合夥人:
Weiheng Chen 陳煒恒, Dan Ouyang 歐陽丹*,
Wanda Woo 胡芷筠, Winfield Lau 劉泳暉

*Not Resident
in Hong Kong

austin
beijing
boston
brussels
hong kong
london
los angeles
new york
palo alto

san diego
san francisco
seattle
shanghai
washington, dc
wilmington, de

 2. Please identify each specific digital asset that you mine or hold. To the extent you hold digital assets other than those that
are mined please disclose how they were acquired and the purpose of holding them. In this regard, we note that you hold a significant
amount of Dogecoin but it is not clear whether it was mined or otherwise acquired.

The Company respectfully advises the
Staff that the Company primarily mines Bitcoin and Ethereum through its cryptocurrency mining business. The Company receives other types
of cryptocurrencies, including Dogecoin, as commission of its mining pool operation, and it temporarily holds cryptocurrencies mined by
its mining pool customers prior to allocating these cryptocurrencies to customers in accordance with their respective computing power
contribution. The Company does not purchase digital assets from third parties. In response to the Staff’s comment, the Company has
revised the disclosure on pages 5 and 6 of the Amendment No.5.

Risk Factors, page 5

 3. Please describe your security and custody arrangements for the digital assets you hold including how you intend to validate existence,
exclusive ownership and software functionality of private digital asset keys and other ownership records.

In response to the Staff’s comment,
the Company has revised the disclosure on pages 6 and 14 of the Amendment No.5.

 4. Add a risk factor addressing that a particular digital asset’s status as a security in any relevant jurisdiction is subject
to a high degree of uncertainty. Your disclosure should acknowledge that there is currently no certainty under the applicable legal test
that such assets are not securities. Also, discuss the potential consequences, including legal or regulatory action, in the event a regulatory
authority or court were to determine that any such asset is a security under the applicable legal framework.

In response to the Staff’s comment,
the Company has revised the disclosure on pages 13 and 14 of the Amendment No.5.

***

If you have any questions regarding the Amendment
No. 5 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
December 16, 2021
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 4 to Registration Statement on Form F-3
Filed December 9, 2021
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.
Amendment No. 4 to Registration Statement on Form F-3
Our Company, page 5
1.We note your disclosure that you primarily mine Bitcoin and Ethereum cryptocurrencies
and that you hold digital assets which primarily consist of Bitcoin, Ethereum and
Dogecoin. Provide a detailed description of the process and framework that you will use
to determine whether any digital assets that you may hold or acquire are securities as
defined in Section 2(a)(1) of the Securities Act of 1933.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 December 16, 2021 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
December 16, 2021
Page 2
2.Please identify each specific digital asset that you mine or hold.  To the extent you hold
digital assets other than those that are mined please disclose how they were acquired and
the purpose of holding them.  In this regard, we note that you hold a significant amount of
Dogecoin but it is not clear whether it was mined or otherwise acquired.
Risk Factors, page 11
3.Please describe your security and custody arrangements for the digital assets you
hold including how you intend to validate existence, exclusive ownership and software
functionality of private digital asset keys and other ownership records.
4.Add a risk factor addressing that a particular digital asset’s status as a security in any
relevant jurisdiction is subject to a high degree of uncertainty.  Your disclosure should
acknowledge that there is currently no certainty under the applicable legal test that such
assets are not securities. Also, discuss the potential consequences, including legal or
regulatory action, in the event a regulatory authority or court were to determine that any
such asset is a security under the applicable legal framework.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten, Staff
Attorney, at (202) 551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址:
    www.wsgr.com

Confidential

December 9, 2021

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    BIT Mining Limited (CIK No. 0001517496)

    Response to the Staff’s Comments on

    Amendment No.3 to the Registration Statement
    on Form F-3 (Registration No. 333-258329) Filed on November 5, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT Mining Limited, a
foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are hereby submitting
to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter
setting forth the Company’s responses to the comments contained in the Staff’s letter dated December 1, 2021 on the Company’s
Amendment No.3 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on November 5, 2021 (the
“Amendment No.3”). Concurrently with the submission of this letter, the Company is filing with the Commission Amendment
No.4 to the Registration Statement (the “Amendment No.4”) and certain exhibits via EDGAR for Staff’s review.

As per the updated disclosure in the Amendment
No. 4, we respectfully submit for your attention that the Company has migrated its crypto mining business to non-PRC jurisdictions and
no longer has any revenue-generating operation in the PRC.

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses. We have included page references in the Amendment No.4 where the disclosure addressing
a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No.4.
To facilitate your review, we have separately delivered to you today five courtesy copies of the Amendment No.4, marked to show changes
to the Amendment No.3, and two copies of the submitted exhibits.

Wilson Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners
合夥人: Weiheng Chen 陳煒恒,
Dan Ouyang 歐陽丹*, Wanda Woo 胡芷筠,
Winfield Lau 劉泳暉

*Not Resident in Hong Kong

austin
beijing   boston   brussels   hong kong   london   los angeles   new york
palo alto

san diego   san francisco   seattle   shanghai   washington, dc   wilmington, de

Page 2

Prospectus Summary

Recent Regulatory Development, Page 7

    1.

    We note your disclosure that your ADSs may be delisted
under the Holding Foreign Companies Accountable Act.  Please clarify that they may also be prohibited from being traded on an over-the-counter market.

In response to the Staff’s comment, the Company
has revised the disclosure on cover page and pages 7 and 8 of the Amendment No.4.

Risk Factors

Our ADSs may be delisted under the HFCA Act..., page 17

    2.
    We note your disclosure regarding the potential consequences to investors if your ADSs are delisted from a securities exchange.  Please include a discussion of the potential for your securities to be prohibited from trading on an over-the-counter market under the Holding Foreign Companies Accountable Act and the consequences to investors.

In response to the Staff’s comment, the Company
has revised the disclosure on pages 17 and 18 of the Amendment No.4.

***

Page 3

If you have any questions regarding the Amendment
No. 4 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/ Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
December 1, 2021
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 3 to Registration Statement on Form F-3
Filed November 5, 2021
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.
Amendment No. 3 to Registration Statement on Form F-3
Prospectus Summary
Recent Regulatory Development, page 7
1.We note your disclosure that your ADSs may be delisted under the Holding Foreign
Companies Accountable Act.  Please clarify that they may also be prohibited from being
traded on an over-the-counter market.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 December 1, 2021 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
December 1, 2021
Page 2
Risk Factors
Our ADSs may be delisted under the HFCA Act..., page 17
2.We note your disclosure regarding the potential consequences to investors if your ADSs
are delisted from a securities exchange.  Please include a discussion of the potential for
your securities to be prohibited from trading on an over-the-counter market under the
Holding Foreign Companies Accountable Act and the consequences to investors.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten,
Staff Attorney, at (202) 551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址:
    www.wsgr.com

Confidential

November 5, 2021

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    BIT Mining Limited (CIK No. 0001517496)

    Response to the Staff’s Comments on

    Amendment No.2 to the Registration Statement on Form F-3 (Registration No. 333-258329) Filed on September 17, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT Mining Limited, a
foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are hereby submitting
to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter
setting forth the Company’s responses to the comments contained in the Staff’s letter dated October 26, 2021 on the Company’s
Amendment No.2 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on September 17, 2021
(the “Amendment No.2”). Concurrently with the submission of this letter, the Company is filing with the Commission
Amendment No.3 to the Registration Statement (the “Amendment No.3”) and certain exhibits via EDGAR to for Staff’s
review.

To facilitate your review, we have separately delivered
to you today five courtesy copies of the Amendment No.3, marked to show changes to the Amendment No.2, and two copies of the submitted
exhibits.

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses. We have included page references in the Amendment No.3 where the disclosure addressing
a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No.3.

Wilson Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners
 合夥人: Weiheng Chen 陳煒恒,
Dan Ouyang 歐陽丹*, Wanda Woo 胡芷筠,
Winfield Lau 劉泳暉

*Not Resident in Hong Kong

austin
beijing   boston   brussels   hong kong   london   los angeles   new york
palo alto

san diego   san francisco   seattle   shanghai   washington, dc   wilmington, de

Page 2

Cover Page

    1.
    Please expand your disclosure on the prospectus cover page to provide a description of how cash is transferred through your organization and state whether any transfers, dividends, or distributions have been made to date.  Similarly, please expand your disclosure in the prospectus summary to provide a clear description of how cash is transferred through your organization.  Quantify any cash flows and transfers of other assets by type that have occurred between you and your subsidiaries, and the direction of the transfer.  Quantify any dividends or distributions that a subsidiary has made to you and which entity made such transfer, and their tax consequences.  Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences.  Your disclosure should make clear if no transfers, dividends, or distributions have been made to date.  Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from your businesses to the parent company and U.S. investors.

In response to the Staff’s comment, the Company has
revised the disclosure on cover page and on pages  9, 10 and 19 of the Amendment No.3.

***

Page 3

If you have any questions regarding the Amendment
No. 3 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very truly yours,

    /s/
    Weiheng Chen

    Weiheng Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
October 26, 2021
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 2 to Registration Statement on Form F-3
Filed September 17, 2021
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 2 to Registration Statement on Form F-3
Cover Page
1.Please expand your disclosure on the prospectus cover page to provide a description of
how cash is transferred through your organization and state whether any transfers,
dividends, or distributions have been made to date.  Similarly, please expand your
disclosure in the prospectus summary to provide a clear description of how cash is
transferred through your organization.  Quantify any cash flows and transfers of other
assets by type that have occurred between you and your subsidiaries, and the direction of
the transfer.  Quantify any dividends or distributions that a subsidiary has made to you and
which entity made such transfer, and their tax consequences.  Similarly quantify dividends
or distributions made to U.S. investors, the source, and their tax consequences.  Your

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 October 26, 2021 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
October 26, 2021
Page 2
disclosure should make clear if no transfers, dividends, or distributions have been made to
date.  Describe any restrictions on foreign exchange and your ability to transfer cash
between entities, across borders, and to U.S. investors.  Describe any restrictions and
limitations on your ability to distribute earnings from your businesses to the parent
company and U.S. investors.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten, Staff
Attorney, at (202) 551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址: www.wsgr.com

Confidential

September 17, 2021

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: BIT Mining Limited (CIK No. 0001517496)

  Response to the Staff’s Comments on

  Amendment No.1 to the Registration Statement on Form F-3 (Registration
No. 333-258329) Filed on September 1, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT Mining Limited, a
foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are hereby submitting
to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter
setting forth the Company’s responses to the comments contained in the Staff’s letter dated September 14, 2021 on the Company’s
Amendment No.1 to the Registration Statement on Form F-3 (Registration No. 333-258329) filed with the Commission on September 1, 2021
(the “Amendment No.1”). Concurrently with the submission of this letter, the Company is filing with the Commission
Amendment No.2 to the Registration Statement (the “Amendment No.2”) and certain exhibits via EDGAR to for Staff’s
review.

To facilitate your review, we have separately delivered
to you today five courtesy copies of the Amendment No.2, marked to show changes to the Amendment No.1, and two copies of the submitted
exhibits.

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses. We have included page references in the Amendment No.2 where the disclosure addressing
a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No.2.

Wilson Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners
 合夥人: Weiheng Chen 陳煒恒,
Dan Ouyang 歐陽丹*, Wanda Woo 胡芷筠,
Winfield Lau 劉泳暉

*Not Resident in Hong Kong

austin   beijing   boston
brussels   hong kong   london   los angeles   new york   palo alto

san diego   san francisco   seattle   shanghai   washington, dc   wilmington, de

Page 2

Cover Page

    1.
    We note your response to prior comment 1. Please revise the cover page to expressly state that the legal and operational risks associated with having operations in China may cause the value of your securities to significantly decline or to be worthless. In addition, please include disclosure on the cover page relating to how recent statements and regulatory actions by China’s government, such as those related to the use of variable interest entities, may impact the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.

In response to the Staff’s comment, the Company has
revised the disclosure on cover page of the Amendment No.2.

Our Risks and Challenges, page 7

    2.
    Please revise your prospectus summary and the corresponding risk factor on page 13 to expressly acknowledge the risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or completely hinder your ability to offeror continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. In addition, revise your prospectus summary and the corresponding risk factor on page 17 to state that the Chinese government may intervene or influence your operations at any time.

In response to the Staff’s comment, the Company has
revised the disclosure on pages 7, 8, 13, 14 and 17 of the Amendment No.2.

 ***

Page 3

If you have any questions regarding the Amendment
No. 2 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very
    truly yours,

    /s/ Weiheng
    Chen

    Weiheng
    Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
September 14, 2021
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Amendment No. 1 to Registration Statement on Form F-3
Filed September 1, 2021
File No. 333-258329
Dear Mr. Yang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our August 17, 2021 letter.
Registration Statement on Form F-3 filed September 1, 2021
Cover Page
1.We note your response to prior comment 1. Please revise the cover page to expressly state
that the legal and operational risks associated with having operations in China may cause
the value of your securities to significantly decline or to be worthless. In addition, please
include disclosure on the cover page relating to how recent statements and regulatory
actions by China’s government, such as those related to the use of variable interest
entities, may impact the company’s ability to conduct its business, accept foreign
investments, or list on a U.S. or other foreign exchange.

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 September 14, 2021 Page 2
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
September 14, 2021
Page 2
Our Risks and Challenges, page 7
2.Please revise your prospectus summary and the corresponding risk factor on page 13 to
expressly acknowledge the risks that any actions by the Chinese government to exert more
oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers could significantly limit or completely hinder your ability to offer
or continue to offer securities to investors and cause the value of such securities to
significantly decline or be worthless. In addition, revise your prospectus summary and the
corresponding risk factor on page 17 to state that the Chinese government may intervene
or influence your operations at any time.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten,
Staff Attorney, at (202) 551-3447 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ke Li, Esq.

CORRESP
1
filename1.htm

    Suite 1509

    15/F Jardine House

    1 Connaught Place

    Central, Hong Kong

    Phone: 852-3972-4955

    Fax: 852-3972-4999

    Website: www.wsgr.com

    香港中環

    康樂廣場一號

    怡和大廈15樓

    1509室

    電話:
    852-3972-4955

    傳真:
    852-3972-4999

    網址: www.wsgr.com

Confidential

September 1, 2021

Mr. Alexandra Barone

Mr. Jeff Kauten

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: BIT Mining Limited (CIK No. 0001517496)

  Response to the Staff’s Comments on

  Registration Statement on Form F-3 (Registration
No. 333-258329) Filed on July 30, 2021

Dear Mr. Barone and Mr. Kauten,

On behalf of our client, BIT Mining Limited, a
foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are hereby submitting
to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter
setting forth the Company’s responses to the comments contained in the Staff’s letter dated August 17, 2021 on the Company’s
registration statement on Form F-3 (Registration No. 333-258329) filed with the Commission on July 30, 2021 (the “Registration
Statement”). Concurrently with the submission of this letter, the Company is filing with the Commission Amendment No.1 to the
Registration Statement (the “Amendment No.1”) and certain exhibits via EDGAR to for Staff’s review.

To facilitate your review, we have separately delivered
to you today five courtesy copies of the Amendment No.1, marked to show changes to the Registration Statement, and two copies of the submitted
exhibits.

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses. We have included page references in the Amendment No.1 where the disclosure addressing
a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No.1.

Wilson Sonsini Goodrich & Rosati

威爾遜‧桑西尼‧古奇‧羅沙迪律師事務所

Partners 合夥人:
Weiheng Chen 陳煒恒, Dan Ouyang 歐陽丹*,
Wanda Woo 胡芷筠, Winfield Lau 劉泳暉

*Not Resident in Hong Kong

austin   beijing   boston
brussels   hong kong   london   los angeles   new york   palo alto

san diego   san francisco   seattle   shanghai   washington, dc   wilmington, de

Page 2

Cover Page

1. Provide prominent disclosure about the legal and operational risks associated with being based in or having the majority of the
company’s operations in China. Your disclosure should make clear whether these risks could result in a material change in your
operations and/or the value of your ADSs or could significantly limit or completely hinder your ability to offer or continue to offer
securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should
address how recent statements and regulatory actions by China’s government, such as those related to the use of variable
interest entities and data security or anti-monopoly concerns, has or may impact the company’s ability to conduct its
business, accept foreign investments, or list on an U.S. or other foreign exchange. Your prospectus summary should address,
but not necessarily be limited to, the risks highlighted on the prospectus cover page.

The Company respectfully advises the Staff that the
Company is actively migrating and expanding its cryptocurrency mining business into international markets outside China. After the
suspension of the Company’s data center operations in China in June 2021 and the disposal of the lottery-related business in
China in July 2021, the substantial majority of the Company’s business operations have been migrated to international markets.
As of the date of this submission, (1) the Company’s remaining operations in China primarily involve the provision of
administrative supports to its cryptocurrency mining business outside China, as well as the provision of information technology
services to its operating entities and mining pools outside China; and (2) the Company does not maintain any variable interest
entity structure or operate any data center in China. In addition, as advised by its PRC counsel, the Company is currently not
subject to any PRC laws and regulations relating to anti-monopoly concerns given the scope and supporting nature of its remaining
business operations in China.

In response to the Staff’s comment, the Company has
revised the disclosure on cover page and pages 5 and 6 of the Amendment No.1.

Our Company, page 4

2. Please revise your prospectus summary to include no more than two pages summarizing the principal factors that make an investment
in the registrant or offering speculative or risky. Refer to Item 105(b) of Regulation S-K. In your summary of risk factors, disclose
the risks that being based in or having the majority of the company’s operations in China poses to investors. In particular, describe
the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the
prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding
the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or
foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of your ADSs. Acknowledge
any risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

In response to the Staff’s comment, the Company has
revised the disclosure on pages 7 and 8 of the Amendment No.1.

Page 3

3. Disclose each permission that you or your subsidiaries are required to obtain from Chinese authorities to operate and issue these
securities to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the CSRC, CAC or
any other entity, and state affirmatively whether you have received
all requisite permissions and whether any permissions have been denied.

The Company respectfully advises the Staff that, as advised
by its PRC counsel, the Company does not believe that it is required to obtain approval from the CSRC or the CAC for any offering contemplated
under the Registration Statement, and that as such, neither the Company nor any of its subsidiaries has applied for or obtained approval
from either the CSRC or the CAC in connection therewith. In response to the Staff’s comment, the Company has revised the disclosure
and included a risk factor relating to CSRC approval and CAC review on pages 6, 14, 17 and 18 of the Amendment No.1.

4. Disclose that trading in your securities may be prohibited under the Holding Foreign Companies Accountable Act if the PCAOB determines
that it cannot inspect or fully investigate your auditor, and that as a result an exchange may determine to delist your securities. If
the PCAOB has been or is currently unable to inspect your auditor, revise your disclosure to so state.

In response to the Staff’s comment, the Company has
revised the disclosure and included a risk factor relating to the risk of our securities being delisted from a U.S. exchange if the PCAOB
determines that it cannot inspect auditor with presence in China on pages 7, 15 and 16 of the Amendment No.1.

5. Please revise to disclose the company's existing digital asset holdings as of the date of the prospectus.

In response to the Staff’s comment, the Company has
revised the disclosure on page 6 of the Amendment No.1.

Risk Factors, page 5

6. Given the Chinese government’s significant oversight and discretion over the conduct of your
business, please revise to separately highlight the risk that the Chinese government may intervene or influence your operations at any
time, which could result in a material change in your operations and/or the value of your ADSs. Also, given recent statements by the Chinese
government indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers, acknowledge the risk that any such action could significantly limit or completely hinder your ability to offer
or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

In response to the Staff’s comment, the Company
has revised the disclosure on pages 9, 10, 13, 14 and 17 of the Amendment No.1.

7. In light of recent events indicating greater oversight by the Cyberspace Administration of China over
data security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight
impacts your business and your offering and to what extent you believe that you are compliant with the regulations or policies that have
been issued by the CAC to date.

Page 4

The Company respectfully advises that, as advised by
its PRC counsel, the Company does not believe that it is required to obtain approval from the CAC for any offering contemplated
under the Registration Statement due to the disposal of the Company’s lottery related business in China, the suspension of its
data centers in China, and the ongoing migration and expansion of its cryptocurrency mining business into international markets
outside China. In response to the Staff’s comment, the Company has revised the disclosure on pages 17 and 18 of the Amendment No.1.

***

Page 5

If you have any questions regarding the Amendment
No.1 to Registration Statement, please contact us via e-mail at rblake@wsgr.com and keli@wsgr.com.

    Very
    truly yours,

    /s/ Weiheng
    Chen

    Weiheng
    Chen

Enclosures

cc:

Xianfeng Yang, Chief Executive Officer, BIT Mining Limited

Richard C. Blake, Wilson Sonsini Goodrich & Rosati, Professional
Corporation

United States securities and exchange commission logo
August 17, 2021
Xianfeng Yang
Chief Executive Officer
BIT Mining Limited
Units 813&815, Level 8, Core F, Cyberport 3
100 Cyberport Road
Hong Kong
Re:BIT Mining Limited
Registration Statement on Form F-3
Filed July 30, 2021
File No. 333-258329
Dear Mr. Yang:
            We have limited our review of your registration statement to those issues we have
addressed in our 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-3 filed July 30, 2021
Cover Page
1.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China.  Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of your ADSs or could significantly limit or completely hinder your
ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.  Your disclosure should address how
recent statements and regulatory actions by China’s government, such as those related to
the use of variable interest entities and data security or anti-monopoly concerns, has or
may impact the company’s ability to conduct its business, accept foreign investments, or

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 August 17, 2021 Page 2
 FirstName LastNameXianfeng Yang
BIT Mining Limited
August 17, 2021
Page 2
list on an U.S. or other foreign exchange.  Your prospectus summary should address, but
not necessarily be limited to, the risks highlighted on the prospectus cover page.
Our Company, page 4
2.Please revise your prospectus summary to include no more than two pages summarizing
the principal factors that make an investment in the registrant or offering speculative or
risky. Refer to Item 105(b) of Regulation S-K.  In your summary of risk factors, disclose
the risks that being based in or having the majority of the company’s operations in China
poses to investors.  In particular, describe the significant regulatory, liquidity, and
enforcement risks with cross-references to the more detailed discussion of these risks in
the prospectus.  For example, specifically discuss risks arising from the legal system in
China, including risks and uncertainties regarding the enforcement of laws and that rules
and regulations in China can change quickly with little advance notice; and the risk that
the Chinese government may intervene or influence your operations at any time, or may
exert more control over offerings conducted overseas and/or foreign investment in China-
based issuers, which could result in a material change in your operations and/or the value
of your ADSs.  Acknowledge any risks that any actions by the Chinese government to
exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your
ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.
3.Disclose each permission that you or your subsidiaries are required to obtain from Chinese
authorities to operate and issue these securities to foreign investors.  State whether you or
your subsidiaries are covered by permissions requirements from the CSRC, CAC or any
other entity, and state affirmatively whether you have received all requisite permissions
and whether any permissions have been denied.
4.Disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or fully
investigate your auditor, and that as a result an exchange may determine to delist your
securities. If the PCAOB has been or is currently unable to inspect your auditor, revise
your disclosure to so state.
5.Please revise to disclose the company's existing digital asset holdings as of the date of the
prospectus.
Risk Factors, page 5
6.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to separately highlight the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of your ADSs.  Also, given recent statements
by the Chinese government indicating an intent to exert more oversight and control over
offerings that are conducted overseas and/or foreign investment in China-based issuers,

 FirstName LastNameXianfeng Yang
 Comapany NameBIT Mining Limited
 August 17, 2021 Page 3
 FirstName LastName
Xianfeng Yang
BIT Mining Limited
August 17, 2021
Page 3
acknowledge the risk that any such action could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.
7.In light of recent events indicating greater oversight by the Cyberspace Administration of
China over data security, particularly for companies seeking to list on a foreign exchange,
please revise your disclosure to explain how this oversight impacts your business and your
offering and to what extent you believe that you are compliant with the regulations or
policies that have been issued by the CAC to date.
            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 Rule 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.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jeff Kauten, Staff
Attorney, at (202) 551-3447 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology

Mail Stop 3561
September  11, 2015

Man San Law
Chief Executive Officer
500.com Limited
500.com Building
Shenxianling Sports Center
Longgang District, Shenzhen 518115
The People’s Republic of China

Re: 500.com Limited
 Form 20 -F for Fiscal Year Ended December 31, 2014
Filed April 27, 2015
File No. 001 -36206

Dear Mr. Law :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
feder al securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable ru les require.

Sincerely,

 /s/ John Dana Brown

John Dana Brown
Attorney -Advisor
Office of Transportation and Leisure

cc: Chris Lin
 Simpson Thacher & Bartlett

CORRESP
1
filename1.htm

September 1, 2015

VIA EDGAR

Office of Transportation and Leisure

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Attention: Mr. John Dana Brown, Attorney-Advisor

  Mr. Donald E. Field, Attorney-Advisor

 Re: 500.com Limited

Form 20-F for Fiscal Year Ended December 31, 2014

Filed April 27, 2015

File No. 001-36206

Gentlemen:

Reference is made to
the letter from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated
August 21, 2015 (the “Comment Letter”), with respect to the annual report on Form 20-F for the fiscal year ended December
31, 2014 (File No. 001-36206) of 500.com Limited, a company organized under the laws of the Cayman Islands (the “Company”),
and the letter from Simpson Thacher & Bartlett, dated August 31, 2015, responding on behalf of the Company to the Staff’s
comment contained in the Comment Letter.

Pursuant to the Comment
Letter, the Company hereby acknowledges that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 · staff comments or changes to disclosure in response to staff comments do not foreclose the Commission
from taking any action with respect to the filing; and

 · the Company may not assert staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

*     *     *     *     *

If you have any questions
in connection with this filing, please contact me at 86-0755-89670323.

    Very truly yours,

    /s/ Min
    Yu

    Min Yu
Chief Financial Officer

CORRESP
1
filename1.htm

        Simpson Thacher & Bartlett

        ICBC Tower, 35th Floor

        3 Garden Road

        Hong Kong

        (852) 2514-7600

        ___________________

    Facsimile (852) 2869-7694

        Direct Dial Number

        +852-2514-7650

        E-Mail Address

        CLIN@stblaw.com

    	August 31, 2015

VIA EDGAR

Office of Transportation and Leisure

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Mr. John Dana Brown, Attorney Advisor

    Mr. Donald E. Field, Attorney Advisor

              Re:
    500.com Limited

    Form 20-F for Fiscal Year Ended December 31, 2014

    Filed April 27, 2015

    File No. 001-36206

Gentlemen:

On behalf of our client,
500.com Limited, a company organized under the laws of the Cayman Islands (the “Company”), we are transmitting this
letter in response to the comment received from the Staff (the “Staff”) of the Securities and Exchange Commission contained
in the Staff’s letter dated August 21, 2015 (the “Comment Letter”), with respect to the Company’s annual
report on Form 20-F for the fiscal year ended December 31, 2014 (File No. 001-36206).

Set forth below is
the Company’s response to the Staff’s comment in the Comment Letter. The Staff’s comment is retyped below
for your ease of reference and are followed by the Company’s response.

*	*	*	*	*

    Leiming
                                         Chen   Daniel Fertig    Adam C. Furber    Anthony
                                         D. King    Celia C.L. Lam   Chris K.H. Lin   Jin
                                         Hyuk Park   Kathryn King Sudol   Christopher K.S. Wong

        Resident
        Partners

        Simpson
        Thacher & Bartlett, Hong Kong is an affiliate of Simpson Thacher & Bartlett LLP with offices in:

    New
    York
      Beijing
    Houston
    London
    Los
    Angeles
    Palo
    Alto
    São
    Paulo
     Seoul
     Tokyo
    Washington, D.C.

Simpson Thacher & Bartlett

General

 1. In January 2015, the Ministry of Commerce of China released a discussion draft of proposed legislation for public comment,
which appears to set out a plan for overhauling Chinese foreign investment laws. To the extent that the discussion draft may be
material to you or your operations please disclose the discussion draft, including how the proposed changes may impact your operations.
In this regard, we note that neither the Risk Factors section on page 6 nor the Regulation of Our Industry section on page 54 reference
or discuss this new proposed legislation.

The Company acknowledges the Staff’s
comment and respectfully advises the Staff that it will disclose the referenced draft legislation, how the proposed regulatory
changes may impact its operations, and any recent developments with respect to the draft legislation in the Company’s next
annual report on Form 20-F.

*	*	*	*	*

Simpson Thacher & Bartlett

If you have any questions regarding this
letter, please do not hesitate to contact me at +(852) 2514-7650 (work) or clin@stblaw.com
(email).

    Very truly yours,

    /s/ Chris K.H. Lin

         Chris K.H. Lin

cc: Zhengming Pan, President

  Min Yu, Chief Financial Officer

Mail Stop 3561
August 21, 2015

Man San Law
Chief Executive Officer
500.com Limited
500.com Building
Shenxianling Sports Center
Longgang District, Shenzhen 518115
The People’s Republic of China

Re: 500.com Limited
 Form 20-F for Fiscal Year Ended December 31, 2014
Filed April 27, 2015
File No. 001 -36206

Dear Mr. Law :

We have reviewed your filing an d 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 comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment  applies to your facts and circumstances , please tell us why in your response.

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

General

1. In January 2015, the Ministry of Commerce of China released a discussion draft of
proposed leg islation for public comment, which appears to set out a plan for overhauling
Chinese foreign investment laws.  To the extent that the discussion draft may be material
to you or your operations please disclose the discussion draft, including how the propose d
changes may impact your operations.  In this regard, we note that neither the Risk Factors
section on page 6 nor the Regulation of Our Industry section on page 54 reference or
discuss this new proposed legislation.

Man San Law
500.com Limited
August 21, 2015
Page 2

 We urge all persons who are respon sible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicab le Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Donald E. Field  at (202) 551 -3680  or me at (202) 551 -3859  with any other
questions.

Sincerely,

 /s/ John Dana Brown

John Dana Brown
Attorney -Advisor
Office of Transportation and Leisure

cc: Chris Lin
 Simpson Thacher & Bartlett