March 6, 2025

Darcy Daubaras
Chief Financial Officer
HIVE Digital Technologies Ltd.
Suite 128, 7900 Callaghan Road
San Antonio, Texas 78229

       Re: HIVE Digital Technologies Ltd.
           Form 40-F for Fiscal Year Ended March 31, 2024
           File No. 001-40398
Dear Darcy Daubaras:

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

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

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

Form 40-F for Fiscal Year Ended March 31, 2024
Notes to the Consolidated Financial Statements
Note 2. Basis of Presentation and Material Accounting Policy Information
(e) Revenue recognition, page 7

1.     Please respond to the following and revise your disclosure in future
filings as
       necessary to address your revenue recognition under IFRS 15:
           Disclose, if true, that the contracts with mining pool operators are
terminable at
           any time by either party without penalty.
           If they are, revise your disclosure to clarify that as a result of
the termination
           rights, the mining pool agreement is continuously renewed for
accounting
           purposes and the accounting duration of your contracts is less than
24 hours.
           Disclose how payments are generally calculated, including the
various
           components of the payment (for example, block reward, transaction
fees, less pool
           operator fee) and the period over which the computations take place
(for example,
           generally midnight to midnight UTC).
           You disclose that the Group recognizes the revenue on a daily basis
on the day it
 March 6, 2025
Page 2

           was received. Disclose whether revenue is recognized on the same day
that
           control of the contracted service transfers to the mining pool
operator. Refer to
           IFRS 15.31.
             Revise your disclosure to clarify the timing and method of valuing
the noncash
           consideration received.
Note 24. Financial Instruments and Risk Management, page 38

2.     We note your disclosure that, "the Company's investment holdings that
are not traded
       in active markets by the Company are considered investments." We further
note that
       you account for the majority of your investments using Level 1 inputs,
which
       indicates quoted prices (unadjusted) in active markets. Please tell us
the following
       concerning your investments:
           How you determined that using Level 1 input is appropriate. Refer to
paragraphs
           76-90 of IFRS 13.
           If you are not using Level 1 inputs, please revise future filings to
disclose the
           specific valuation techniques and inputs used to determine fair
value and make
           sure your disclosures are consistent with the requirements starting
in paragraph 91
           of IFRS 13.
Note 25. Digital Currency and Risk Management, page 47

3.     We note your disclosure of the impact of a 5% variance in price for
Bitcoin. Please
       tell us how you determined that a 5% impact was appropriate given the
price volatility
       of Bitcoin in the periods presented. Please provide more robust
sensitivity analysis in
       future filings. Refer to paragraphs 40-42 of IFRS 7.
        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact David Irving at 202-551-3321 or Jason Niethamer at
202-551-3855
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Crypto
Assets