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United States securities and exchange commission logo





                              April 3, 2024

       James Gernetzke
       Chief Financial Officer
       Exodus Movement, Inc.
       15418 Weir Street, Suite #333
       Omaha, NE 68137

                                                        Re: Exodus Movement,
Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed February 28,
2024
                                                            File No. 000-56643

       Dear James Gernetzke:

                                                        We have reviewed your
filing 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 and any amendment you may file in
response to this letter,
       we may have additional comments.

       Registration Statement on Form 10

       General

   1.                                                   You state that you
provide support for over 21,000 crypto assets. Please provide a
                                                        description of your
internal policies and procedures for how you determine whether crypto
                                                        assets, including NFTs
and staking products, are securities within the meaning of the U.S.
                                                        federal securities
laws. Also clarify that such processes are risk-based assessments made
                                                        by the company and are
not legal standards binding on any regulatory body or court.
                                                        Further, please include
a risk factor that addresses the specific risks inherent in your
                                                        policies and procedures
for determining whether or not a crypto asset is a security, and
                                                        describe the potential
regulatory risks under the U.S. federal securities laws if such crypto
                                                        assets are determined
to be securities. Similarly please address how you determine that
                                                        you are in compliance
with the rules, regulations and laws of the jurisdictions in which
                                                        you offer your products
and services.
   2.                                                   Please revise to
disclose your policies related to whether you provide services for crypto
                                                        assets that are
securities, and, if so, how you do so in compliance with the federal
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FirstName   LastNameJames Gernetzke
Exodus Movement,     Inc.
Comapany
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         securities laws and the risks to your business if you are found to be
engaging in
         transactions for unregistered securities in violation of the federal
securities laws. In this
         regard, we note that your website indicates you offer staking products
for Cosmos and
         Tezos, which have been identified as securities in separate SEC
complaints.
3.       Please provide to us a list of the each of the crypto assets material
to your business,
         organized by the aggregate volume of transactions involving the crypto
asset that also
         includes the blockchain on which each crypto asset exists, the volume
of transactions
         involving the crypto asset in each jurisdiction in which you provide
products and services
         for the crypto asset and the services you provide for each. In
addition, revise your
         registration statement to include a table that, by volume of
transactions, lists the crypto
         assets that are material to your business, and describe the
characteristics of these crypto
         assets. Also disclose whether there are any jurisdictions in which you
do not provide
         services related to any of these crypto assets.
4.       We refer you to our December 2022 Sample Letter to Companies Regarding
Recent
         Developments in Crypto Asset Markets, located on our website at the
following address:

https://www.sec.gov/corpfin/sample-letter-companies-regarding-crypto-asset-
         markets. Please consider the issues identified in the sample letter as
applicable to your
         facts and circumstances, and revise your disclosure accordingly.
Cover Page

5.       Please revise your filing to provide the address of your principal
executive offices.
Business, page 1

6.       Please revise to identify the jurisdictions in which you offer your
platform and services
         and disclose the percentage of revenue earned in each. In addition, we
note that U.S.
         federal and state and foreign laws prohibit you from making available
your platform or
         certain of its functionalities in all jurisdictions. Please disclose
the methods you use to
         prohibit the Exodus Platform and certain of its functionalities from
being accessed in
         such jurisdictions, and identify these jurisdictions and
functionalities. Also revise your
         disclosure in the Regulatory Environment section on page 6 to discuss,
to the extent
         material, the laws, rules and regulations that impact your business in
the jurisdictions in
         which you offer your platform and services. For example, you disclose
on page 15 that
         you offer products and services in China. If material, describe the
laws, rules and
         regulations in China regarding crypto assets and any other laws, rules
and regulations that
         may impact your business.
7.       Please identify the crypto assets you hold for your own account. In
this regard, we note
         your disclosure on page 25 that, as of December 31, 2023, you held
Bitcoin, Ethereum,
         USDC and "other digital assets." To the extent that you hold your
crypto assets on an
         exchange, please identify the exchange. To the extent that they are
held with a third-party
         custodian, please identify the custodian and describe the material
terms of the agreement,
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Exodus Movement,     Inc.
Comapany
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         including:
             disclose how the custodian stores the private keys, including the
percentage that are
              held in cold storage, and the geographic location of where they
are stored;
             disclose whether your assets are comingled with the assets of
other customers;
             identify who has access to the private key information;
             disclose whether any entity is responsible for verifying the
existence of your crypto
              assets; and
             disclose whether and to what extent the custodian carries
insurance for any losses of
              the crypto assets it holds for you.
         To the extent that you self-custody your crypto assets, please revise
to disclose your
         policies and procedures related to storing the private keys, including
whether they are held
         in cold or hot storage, the geographic location where they are stored
and who has access to
         the private keys. In addition, we note your disclosure on page 12 that
you do not have
         insurance that covers your Bitcoin in the event of loss or fraud.
Please revise to clarify, if
         true, and on page 12 that you do not have insurance that covers your
crypto assets. If you
         do have insurance that covers your crypto assets, please revise to
disclose to what extent
         the insurance covers the loss of your crypto assets.
8.       Please revise to disclose whether the fees you earn are paid in fiat
currency or crypto
         assets. To the extent that the fees are paid in crypto assets, please
disclose the crypto
         assets that you accept as payment, how and when you value the crypto
assets accepted as
         payment, your policies related to monetizing the crypto assets, where
you exchange the
         crypto assets for fiat currency and whether you have agreements with
any of the third-
         party exchanges or counter parties that you use for such purposes. If
you do have
         agreements with third-party exchanges or the counter parties used to
exchange your crypto
         assets, please disclose the material terms of the agreements. In
addition, to the extent that
         you accept crypto assets as payment, please disclose whether you or
the API pays the
         expenses, such as gas fees, related to the transfer of the crypto
assets from the API to you.
9.       We note your disclosure on your YouTube channel that you distribute
USDC to users that
         recommend your product to others. Please revise to disclose the
circumstances in which
         you distribute USDC and the amount of USDC distributed to users of
your platform.
10.      Please revise to disclose whether and to what extent you have
insurance for any losses of
         assets in your users' wallets.
11.      Please describe the AML, KYC and any other procedures conducted by you
or for you by
         third parties to determine, among other things, whether the
counter-party in any
         transaction is not a sanctioned entity or whether a user of your
platform is not a sanctioned
         entity. Similarly, please describe the AML, KYC and any other
procedures related to the
         sale or acquisition of crypto assets for your own account.
Our Company, page 1

12.      Please revise here to disclose that you are a controlled company and
that Jon Paul
         Richardson, your CEO and director, and Daniel Castagnoli, a director,
control 85% of the
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         voting power of your outstanding capital stock and that holders of
your Class B common
         stock collectively control 98% of the voting power of your outstanding
common stock.
13.      Please revise to clarify what you mean by the    trustworthiness of a
bank   s online
         portal." In this regard, we note that you are not a banking
institution or otherwise a
         member of the FDIC and that the assets held in your wallets are not
subject to the
         protections of depositors with FDIC institutions and that crypto asset
transfers, which due
         to human error, theft or criminal action, may be improperly
transferred from a
         user's wallet and never recovered due to the characteristics of crypto
assets and the
         blockchain.
Our Industry, page 1

14.      Please revise your disclosure in this section to provide a balanced
description. For
         example purposes only, we note the following:
             you state that    [a]s a result, blockchain technology has a
reputation of being difficult
             to access and use, and the current options for managing digital
assets do not provide
             integrated or seamless solutions    but do not explain that many
crypto asset exchanges
             allow users to access multiple blockchains through the exchanges
 platforms;
             you state that certain cryptocurrencies are primarily used to pay
for goods and
             services and are often considered a substitute for gold, cash or
forms of electronic
             payment but do not discuss the limited use of crypto assets to pay
for retail and
             commercial services;
             you discuss privacy coins but do not discuss the ban of such
crypto assets in several
             jurisdictions or that the anonymity provided by the crypto assets
facilitates the use of
             these crypto assets for illicit financing and crime;
             you state that crypto assets    can also be transferred in real
time, often with no or low
             fees,    but do not address the volatility of transfer fees and
settlement times;
             you state that    [o]ften wallets have cumbersome interfaces,
but do not disclose
             that the private key that your users must enter to utilize the
crypto assets in their
             wallets on your platform is an alphanumeric code with hundreds of
digits, which, if
             lost, renders the assets in the wallets lost; and
             you state that "[s]tablecoins are cryptocurrencies whose value is
connected to an asset
             that will not significantly fluctuate in value" but do not discuss
the potential for
             significant fluctuations in value.
Our Solution - The Exodus Platform, page 3

15.      We note your disclosure on page 3 that you are    adapting and
innovating the Exodus
         Platform to support [y]our users    ability to store other types of
valuable assets such as
         personal information, traditional fiat currencies and other tokenized
financial
         products.    Please revise to disclose the assets that your wallets
currently are able to hold.
         In addition, please discuss your plans for developing additional
wallet capabilities, the
         steps involved for such development, the related costs, the source of
the capital necessary
         for the development and any challenges you may encounter, including
compliance with
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FirstName   LastNameJames Gernetzke
Exodus Movement,     Inc.
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         the relevant laws, rules and regulations in each of the jurisdictions
in which you
         operate. In addition, please revise to clarify what you mean by "other
tokenized financial
         products."
Our Strategy
Elevate Technology, page 3

16.      We note that, on page 3, you disclose that "[c]urrently products do
exist to permit users to
         migrate from fiat currency to digital assets; however, they often have
poor user
         interface/user experience (   UI/UX   ) designs and require numerous
transactions to
         move between different types of digital assets    but it appears that
one of the ways you
         facilitate transfers of crypto assets is by giving users access to
third-party exchanges.
         Please clarify how the use of your platform differs from the use of
third-party exchanges,
         and clarify what you mean by your disclosure that "[t]he Exodus
Platform is asset
         agnostic, meaning [that you] have the ability to operate properly
irrespective of the type of
         digital asset.
Our Products and Services
Exodus Platform, page 4

17.      Please identify all of the products and services you offer on your
platform, identify any of
         your products and services that you do not offer to U.S. users and
discuss the different
         pricing models you use depending on whether a customer is a U.S.
person, including the
         reasons for the use of such different pricing models. In addition,
please identify all of your
         API providers, including the jurisdiction of each, and disclose the
material terms of the
         agreements you have with the providers, including how you earn fees
from each. In this
         regard, we note your disclosure on page 45 in your financial
statements that addresses
         exchange aggregation, fiat onboarding and staking revenue earned
through an API
         provider.
18.      Please identify the fiat currencies that may be used to purchase
crypto assets and the fiat
         currencies that may be received for the sale of crypto assets on or
through your platform.
19.      We note your disclosure that you "have a streamlined approach to
aggregate the
         exchanges and aim to provide users with the best exchange rate within
their jurisdictional
         limitations." Under an appropriately captioned heading, please revise
to describe in detail
         what your Exchange Aggregator is and how it works. Please revise to
identify the
         exchanges you use, the jurisdiction of each exchange and whether you
have separate
         agreements with each exchange or whether one of your APIs provides the
connection with
         the third-party exchanges. In addition, please disclose whether the
third-party exchanges
         that users may access through your platform provide services for the
21,000 types of
         crypto assets that users may hold in their wallets on your platform.
20.      We note your disclosure that users can "send, receive and swap over
21,000 crypto assets
         without having to access centralized exchanges or trade across
multiple order
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FirstName   LastNameJames Gernetzke
Exodus Movement,     Inc.
Comapany
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       3, 2024
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         books." Please revise to describe how users send, receive and swap
crypto assets on your
         platform without accessing centralized exchanges, and describe your
involvement in such
         transfers.
21.      We note your disclosure that the "platform also provides important
information for users
         regarding accurate and real-time information on crypto asset prices
and other relevant
         market data." Please describe how you determine the real-time crypto
asset prices and
         describe the "other relevant market data" that you provide on your
platform.
22.      We note your disclosure that the creation of the Exodus Platform has
been downloaded
         over 12.4 million times as of December 31, 2023. Please revise to
disclose how many
         times your platform was downloaded during the fiscal year ended
December 31, 2023. We
         also note your disclosure that "[a]s of December 31, 2023, [y]our
users have swapped
         approximately $12.3 billion digital assets." Please revise to disclose
the volume of
         transactions during the most recently completed fiscal year. In
addition, we note your
         disclosure on page 8 that    [t]he success of [y]our business depends
on [y]our ability to
         attract and retain Exodus Platform users.    Please revise to disclose
the metrics you use to
         evaluate your attraction and retention levels. In addition, we note
your disclosure on page
         23 regarding monthly active users. Please revise to provide a
definition of    monthly active
         users    and disclose how many you had throughout the most recently
completed fiscal year
         and how many you had as of December 31, 2023.
23.      Please revise to disclose your policies and procedures relating to
forks and airdrops of
         crypto assets in situations where your wallet does not support the
incidental right. In
         addition, to the extent that users may need to forgo potential
economic benefits associated
         with incidental rights, please include risk factor disclosure.
Staking, page 4

24.      Please identify the crypto assets for which you offer staking
products, and revise to
         disclose the terms of each of the staking products offered on your
platform. In addition,
         please disclose the risks to users of utilizing the staking products
offered on your platform.
Human Capital Management, page 6

25.      We note your disclosure on page 6 that you pay your employees in
Bitcoin and your
         disclosure on page 12 that the salaries are denominated in U.S.
dollars. Please revise to
         disclose how and when you value the Bitcoin used for compensation. In
addition, we note
         your disclosure that 130 of your team members are located outside the
United
         States. Please identify the countries in which your team members are
located and the
         number of employees located in each jurisdiction. In addition, please
disclose when and
         where you obtain the Bitcoin used to pay your employees and
contractors and whether
         you or the employees and contractors pay the transfer costs associated
with the transfer of
         Bitcoin.
26.      We note your disclosure that you had 195 "full time equivalents" as of
December 31, 2023
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FirstName   LastNameJames Gernetzke
Exodus Movement,     Inc.
Comapany
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         and that TriNet co-employs your U.S. team members. Please revise to
explain what you
         mean by "full time equivalents," and disclose the material terms of
your agreement with
         TriNet, including the term and termination provisions.
Uncertainty and Volatility in the Digital Asset Markets, page 6

27.      Please revise to disclose here that the FTX app was available on the
Exodus Platform until
         you removed it in November 2022. In addition, please disclose here
that Alameda
         Research Ventures LLC held 42.2% of your Class A common stock as of
December 31,
         2023.
Risk Factors, page 8

28.      We note that several of your risk factors are generally applicable to
companies in your
         industry and not specific to Exodus Movement. Please revise your risk
factor disclosure to
         provide specific examples that have occurred at your company or to
third parties with
         which you conduct business. For example purposes only and not as an
exhaustive list, we
         note the following:
             You address the risks of disruptions in your agreement with
third-party APIs. To the
             extent that you have experienced any such disruptions, please
discuss.
             You discuss the risks related to malware, security breaches or
other cybersecurity
             incidents. To the extent that you have or your APIs have been
impacted by any
             material incidents, please discuss.
             You discuss disputes with users and other third parties. To the
extent that you have
             experienced any material disputes, please discuss.
             You discuss licenses or other authorizations that may be required
in certain
             states. Please identify the percentage of your users and any
services that
             you provide that will be impacted by such regulations, and, to the
extent material,
             please discuss these regulations in greater detail in your
Regulatory Environment
             section on page 6.
29.      Please provide a materially complete description of the risks related
to the crypto assets
         that you support, including:
             the use of crypto assets in illicit transactions;
             the lack of adoption of and ability to use crypto asset to
purchase goods;
             the risk of a "51%" attack on certain crypto asset networks;
             the risk presented by the concentration of ownership of a crypto
asset; and
             the risk that rewards for mining Bitcoin are designed to decline
over time, which may
              lessen the incentive for miners to process and confirm
transactions on the Bitcoin
              network.
         In addition, please discuss the extent to which material aspects of
the business and
         operations of trading platforms are not regulated. For example, please
address the fact
         that trading platforms are not subject to regulation in a similar
manner as other regulated
         trading platforms, such as national securities exchanges or designated
contract
         markets. Also discuss the risk of fraud, manipulation, front-running,
wash-trading,
 James Gernetzke
Exodus Movement, Inc.
April 3, 2024
Page 8
         security failures or operational problems at trading platforms,
including your own or ones
         that may be accessed through your platform.
30.      Please add a risk factor that addresses the risk to your users if you,
one of your
         subsidiaries or one of your APIs experiences insolvency or bankruptcy.
31.      To the extent material, please include risk factor disclosure
addressing the risks associated
         with operating as an unregistered investment company.
Risks Related to Our Business
Our holdings of digital assets expose us to potential risks, page 12

32.      Please revise to add quantitative examples demonstrating the
volatility of bitcoin and
         other crypto assets you hold.
Risks Related to Regulation
The regulatory regime governing blockchain technologies, page 16

33.      Please add a separate risk factor that addresses the liability to the
company if Exodus
         users engage in illegal or criminal activity on or through the Exodus
platform. Similarly
         please add a separate risk factor that addresses the liability to the
company if the API
         providers fail to comply with the rules, laws and regulations in the
jurisdictions in
         which they provide services to your users.
Risks Related to Ownership of Our Common Stock
The Company is currently a "controlled company", page 22

34.      Please revise to clarify that you are not listing your securities on a
national securities
         exchange.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
23

35.      Please revise your next amendment to break out the material components
of general and
         administrative expenses. Discuss any material trends between periods.
Refer to Item
         303(b)(2) of Regulation S-K.
Director Independence, page 32

36.    We note your disclosure that you do not currently have an audit
committee, compensation
       committee or nominating and corporate governance committee but that your
board of
       directors intends to establish an audit committee composed entirely of
independent
FirstName LastNameJames Gernetzke
       directors. Please disclose when the board of directors intends to
establish these
Comapany    NameExodus
       committees.   In thisMovement,
                             regard, we Inc.
                                        note that you have added two new
independent directors to
April 3,your
         2024board
              Pagein8 fiscal year 2024.
FirstName LastName
 James Gernetzke
FirstName   LastNameJames Gernetzke
Exodus Movement,     Inc.
Comapany
April       NameExodus Movement, Inc.
       3, 2024
April 93, 2024 Page 9
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FirstName LastName
Legal Proceedings, page 32

37.      We note your disclosure on page 16 that you are not in compliance with
the United
         Kingdom Financial Conduct Authority rules and that you have been
placed on the
         Warning List. Please revise to disclose how you are in non-compliance
and the impact if
         you are unable to reach an agreement with the United Kingdom Financial
Conduct
         Authority.
Description of Registrant's Securities to be Registered
Common Stock, page 34

38.      Please revise to disclose whether you issue and have outstanding
tokenized shares of
         common stock. To the extent that you do, please disclose the rights of
the holders of the
         tokenized shares, how such rights are memorialized, how you comply
with the proxy rules
         in connection with tokenized shares, whether and, if so, when and how
such rights
         or characteristics can be modified, whether the token has been
subjected to a third-party
         security audit of the code and, if so, who conducted the audit and the
results of the audit,
         the blockchain on which it exists and the AML/KYC procedures you
preform for issuance
         and other transfers.
39.      Please revise to clarify whether your shares of common stock are made
available on an
         ATS. In this regard, we note your disclosure on page 32 that you
ceased making your
         shares of Class A common stock available on tZero and on Securitize
Markets.
Financial Statements
Note 2. Summary of Significant Accounting Policies
Cash and Cash Equivalents, page 43

40.      Please tell us why you classify your mutual funds as a cash
equivalent. If the disclosure is
         meant to refer to money market accounts, please revise to clarify.
Refer to the definition
         of cash equivalents in the FASB Master Glossary.
Accounts Receivable, page 44

41.      Please revise your next amendment to expand your disclosure related to
Accounts
         Receivable to provide the following:
             A rollforward of accounts receivable in the periods presented;
             the specific GAAP guidance you followed to form your accounting
policy for your
             allowance for doubtful accounts;
             if you have had any receivables charged-off in the periods
presented; and
             your charge-off policy under ASC 310-10-35-41.
Exchange Aggregation, Fiat Onboarding, and Staking Revenue Earned Through an
API
Provider, page 45

42.      On page 43, you disclose that you developed an un-hosted
self-custodial digital asset
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         wallet on the Exodus Platform and you contract with third parties to
provide various
         services to users that utilize your wallet through the platform.
Please respond to the
         following:
             Revise the disclosure to clarify the nature of your performance
obligation(s). Clarify
              how many performance obligations are in the contract and, if more
than one, how you
              allocate the transaction price to the separate performance
obligations in the contract.
             Summarize for us the pertinent rights and obligations of the
parties in your
              agreements with API providers and, if applicable, end users.
             Disclose who is your customer. Refer to ASC 606-10-15-3.
             Tell us whose customer is the end user and why. Tell us whether
the end user enters
              into a contract with the API providers.
             You disclose that you have determined that for your transaction
based contracts, you
              are an agent under ASC 606. Provide us with your accounting
analysis
              supporting this determination. Refer to ASC 606-10-55-36 through
55-40.
             Disclose the form of consideration and timing of payment under
your agreements.
             If the form of consideration is noncash, disclose your accounting
policy for the
              timing and method of measuring the noncash consideration. Refer
to ASC 606-10-32-
              21 to 32-24.
             For transaction-based API fees, you disclose that you recognize
revenue when
              the API interaction is complete. For non-transaction-based API
fees, you disclose that
              you recognize revenue based on when performance obligations in
the underlying
              contracts have been identified, priced, allocated, and satisfied.
                o  Explain to us how the timing of your revenue recognition
policy considered
                   when you satisfy your performance obligations by
transferring a promised good
                   or service to a customer and the customer obtaining control
of that good or
                   service. Refer to ASC 606-10-25-23.
                o  Disclose whether you recognize revenue at a point in time or
over time and
                   why.
                o  For both types of revenues, revise the disclosure to clarify
when you recognize
                   revenue and how you considered the transfer of control.
             You disclose on pages 16 and 17 that you charge your third-party
providers a
              monthly subscription fee for exchanges made by U.S. persons
trading digital assets
              and you charge a percentage of the digital assets exchanged for
exchanges made by
              non-U.S. persons. Revise your disclosure to discuss how you
account for the monthly
              subscription fees. Explain whether the monthly subscription fee
is recurring revenue.
43.      Provide us with your accounting analysis regarding whether you provide
a service to
         safeguard end users crypto-assets and whether you, or an agent acting
on your
         behalf, is therefore obligated to secure these crypto-assets and
protect them from loss,
         theft or other misuse. Your analysis should include how you considered
the regulatory,
         technological and legal risks and loss exposure associated with
safeguarding the crypto-
         assets for the end users. In your response address whether the end
user can transact
         without any involvement by you and whether you have the ability to
recover a customer   s
         private key or their crypto assets. If applicable, tell us how you
account for
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         any safeguarding obligation and provide us a detailed analysis,
including contextual
         citation to authoritative guidance, that supports your determination.
Note 6. Intangible Assets
Digital Assets, page 50

44.      Please revise your next amendment to include a rollforward for each of
your digital assets
         for the periods presented.
45.      With respect to the table of non-cash activities, please tell us why
the conversion of digital
         assets and USDC to cash is a included as a non-cash activity. Please
address the
         following:
             Tell us how you considered the classification in the statement of
cash flows of
              any cash proceeds from sales of digital assets accounted for as
intangible assets and
              separately sales of USDC accounted for as financial assets and
whether those
              proceeds should be classified as operating or investing
activities; and
             Tell us how you considered the classification in the statement of
cash flows of the
              non-cash impact of the related realized gain on sale or
settlement.
Note 10. Income Taxes, page 53

46.      We note you have recorded a partial allowance for your deferred tax
asset at December
         31, 2023 and have released a portion of the valuation allowance during
fiscal year
         2023. Please provide us with specific detailed information to support
the realizability of
         the net deferred tax asset, and your accounting, at December 31, 2023
under the guidance
         in ASC 740-10-30-16 through 25.
Note 13. Earnings per Share, page 56

47.      On page 51, you disclose that the rights of the holders of Class A and
Class B common
         stock are identical, except with respect to voting and conversion
rights. Please respond to
         the following:
             Show us how you calculated the basic and diluted net income (loss)
per share for the
              Class A and Class B shares, including the allocation of net
income (loss) to each
              class;
             Show us how you determined the diluted weighted average common
shares for each
              class for fiscal 2023;
             Tell us why the earnings per share for each class are different if
the dividend rights
              for each class are identical;
             If the two classes of common stock have different dividend rates,
tell us your
              consideration of ASC 260-10-45-59A and 45-60B; and
             Based on your response, consider whether you should update your
earnings per share
              accounting policy disclosure on page 47.

       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
 James Gernetzke
Exodus Movement, Inc.
April 3, 2024
Page 12

action by the staff.

       Please contact Kate Tillan at 202-551-3604 or David Irving at
202-551-3321 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at 202-551-3758
with any
other questions.



                                                          Sincerely,
FirstName LastNameJames Gernetzke
                                                          Division of
Corporation Finance
Comapany NameExodus Movement, Inc.
                                                          Office of Crypto
Assets
April 3, 2024 Page 12
cc:       Thomas J. Kim
FirstName LastName
</TEXT>
</DOCUMENT>
