November 21, 2024

Jeffrey Lucas
Chief Financial Officer
Bitfarms Ltd.
110 Yonge Street
Suite 1601
Toronto, Ontario
Canada M5C 1T4

        Re: Bitfarms Ltd.
            Form 40-F for the Fiscal Year Ended December 31, 2023
            Response dated September 9, 2024
            File No. 001-40370
Dear Jeffrey Lucas:

        We have reviewed your September 9, 2024 response to our comment letter
and have
the following comments.

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

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our July 31,
2024 letter.

Form 40-F for the Fiscal Year Ended December 31, 2023
Consolidated Statements of Cash Flows, page F-7

1.     We acknowledge your response to prior comment 2. As previously
requested, and
       consistent with the requirements of IAS 7.16(b), please revise to
classify the proceeds
       from sales of your digital assets classified as intangible assets within
investing
       activities.
Note 3. Basis of Presentation and Material Accounting Policy Information
Revenue Recognition, page F-12

2.     In your response to the second bullet of prior comment 3, you told us
that you decide
       when to provide services to the mining pool operator. In order to
provide a more
 November 21, 2024
Page 2

       fulsome description of your accounting policy related to mining revenue,
we continue
       to believe your disclosure should include an explanation that your
enforceable right to
       compensation begins when, and continues as long as, you provide
services, and you
       decide when to provide services under the contracts. Please revise your
disclosure in
       future filings accordingly or further explain to us how your current
disclosure includes
       that information.
       Please contact Kate Tillan at 202-551-3604 or Rolf Sundwall at
202-551-3105 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Crypto
Assets