United States securities and exchange commission logo





                              March 24, 2021

       Jon Paul Richardson
       Chief Executive Officer
       Exodus Movement, Inc.
       15418 Weir Street, #333
       Omaha, NE 68137

                                                        Re: Exodus Movement,
Inc.
                                                            Amendment No. 1 to
                                                            Offering Statement
on Form 1-A
                                                            Filed March 17,
2021
                                                            File No. 024-11468

       Dear Mr. Richardson:

             We have reviewed your amended offering statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
12, 2021 letter.

       Amendment No. 1 to Offering Statement on Form 1-A

       Offering Summary
       Digital Format Exodus Common Stock, page 1

   1.                                                   Please disclose here
that if a seller transfers or sells Class A common stock and the seller
                                                        possesses but does not
transfer to the buyer the number of Common Stock Tokens that
                                                        corresponds to the
amount of Class A common stock sold, the Transfer Agent will remove
                                                        the relevant amount of
Common Stock Tokens from the seller   s digital wallet and burn
                                                        them, so that they no
longer exist. We note your disclosure in this regard in the last
                                                        paragraph on page 120.
 Jon Paul Richardson
Exodus Movement, Inc.
March 24, 2021
Page 2
Common Stock Tokens, page 114

2.       Please clarify here whether Class A common stock holders will be able
to opt-out of
         receiving the Tokens and, if so, describe the process for holders to
so opt-out.
       You may contact Mark Brunhofer at 202-551-3638 or Bonnie Baynes at
202-551-4924 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or J. Nolan McWilliams at
202-551-3217 with any
other questions.



FirstName LastNameJon Paul Richardson                        Sincerely,
Comapany NameExodus Movement, Inc.
                                                             Division of
Corporation Finance
March 24, 2021 Page 2                                        Office of Finance
FirstName LastName