September 11, 2025

Bruce M. Rodgers
Chief Executive Officer
LM Funding America, Inc.
1200 West Platt Street, Suite 100
Tampa, FL 33606

        Re: LM Funding America, Inc.
            Registration Statement on Form S-3
            Filed August 27, 2025
            File No. 333-289887
Dear Bruce M. Rodgers:

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

        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.     Given the size and nature of the resale offering relative to the
outstanding shares of
       common stock held by non-affiliates, it appears that this transaction
may be an
       indirect primary offering by or on behalf of the company. Please provide
us with your
       legal analysis as to why the transaction covered by the registration
statement should
       be regarded as a secondary offering that is eligible to be made on a
delayed or
       continuous basis under Rule 415(a)(1)(i) of the Securities Act. For
guidance, please
       refer to Question 612.09 of the Securities Act Rules Compliance and
Disclosure
       Interpretations.
 September 11, 2025
Page 2
Prospectus Summary
Our Business, page 3

2.     We note that you have a cryptocurrency treasury strategy focused on
Bitcoin. Please
       expand your disclosure to describe your plan of operations for the next
twelve months
       by describing the source of capital for your acquisition of Bitcoin,
including when you
       intend to purchase Bitcoin with the proceeds from the PIPE Offering and
the
       securities purchase agreement.
3.     Please expand to disclose the policies and procedures you have in place
or intend to
       adopt that govern when you exchange cash, or other assets, for Bitcoin
and when you
       monetize your Bitcoin. Additionally, disclose whether you have policies
or will
       establish policies governing the percentage of your treasury holdings
that will be
       Bitcoin, the percentage of your treasury that is currently invested in
Bitcoin, and
       whether you intend to acquire other crypto assets. Please disclose
whether you intend
       to hedge your Bitcoin exposure, and, if so, please describe your hedging
strategy.
4.     Please revise to identify the custodian of your custodially-held assets.
Additionally,
       describe the material terms of your custodial services agreement,
including the term,
       termination provisions, whether your assets are held in segregated
accounts, the
       identity of entities that have access to the Bitcoin, whether any entity
is responsible
       for verifying the existence of the Bitcoin, and the insurance coverage
of your Bitcoin
       holdings. Additionally, disclose where your third-party custodian is
chartered and how
       it is regulated. Further, please file your custodial services agreement
as an exhibit to
       your registration statement or tell us why you are not required to do
so.
5.     Please revise to include a materially complete description of Bitcoin
and the Bitcoin
       blockchain, including, for example, a description of the lifecycle of
Bitcoin, the use
       case of Bitcoin, including its purpose, use and/or functions, the market
cap of Bitcoin,
       the circulating supply of Bitcoin, the maximum supply of Bitcoin, the
average trading
       volume of Bitcoin, the launch date of Bitcoin and the Bitcoin
blockchain, and the
       governance of the Bitcoin blockchain.
Risk Factors
Risks Related to our Cryptocurrency Treasury Strategy, page 4

6.     Please revise your risk factor disclosure to address the following:
           Describe factors potentially impacting the price of Bitcoin such as
competition
           from other crypto assets and trends in the level of adoption of
Bitcoin relative to
           other crypto assets.
           Provide quantitative information that demonstrates the volatility of
Bitcoin.

        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.
 September 11, 2025
Page 3

      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:   Curt Creely