August 21, 2025

Steven Gutterman
Chief Executive Officer
Gryphon Digital Mining, Inc.
1180 North Town Center Drive, Suite 100
Las Vegas, NV 89144

       Re: Gryphon Digital Mining, Inc.
           Registration Statement on Form S-3
           Filed August 6, 2025
           File No. 333-289278
Dear Steven Gutterman:

       We have conducted a limited review of your registration statement and
have the
following comment.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
General

1.     Please provide an analysis supporting your conclusion that the
registrant is eligible to
       use Form S-3 to register this offering considering the shareholders of
Gryphon Digital
       Mining, Inc. are voting on proposals necessary to complete the
acquisition of the
       company by American Bitcoin Corp. In this regard, we note General
Instruction I.A.6
       to Form S-3. If you are not eligible to use Form S-3 for this offering,
please withdraw
       this registration statement and refile on an appropriate form.
 August 21, 2025
Page 2

        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 Rules 460 and 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 David Gessert at 202-551-2326 or Sandra Hunter Berkheimer
at 202-
551-3758 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Crypto
Assets
cc:   Adam Berkaw, Esq.