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                            May 28, 2024

       Sidney Chan
       Chief Executive Officer and Chief Financial Officer
       ALR Technologies SG Ltd.
       9 Raffles Place
       #26-01 Republic Plaza
       Singapore 048619

                                                        Re: ALR Technologies SG
Ltd.
                                                            Annual Report on
Form 20-F for the Fiscal Year Ended December 31, 2023
                                                            Filed April 30,
2024
                                                            File No. 000-56491

       Dear Sidney Chan:

              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.

       Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2023

       Operating and Financial Review and Prospects
       Results of Operations, page 29

   1.                                                   Please provide an
introduction note to the table presentation of results of operations
                                                        explaining that amounts
presented have been rounded to the nearest thousand. Further,
                                                        consider including
negative brackets around amounts for your line items of loss before
                                                        other items and net
loss, similar to the presentation included in your consolidated
                                                        statements of
operations on page F-5.

   2.                                                   Refer to the discussion
of Loss before Other Items and Share-based Compensation on
                                                        page 30. We note your
computation and discussion of loss before other items and share-
                                                        based compensation
appears to be a Non-GAAP financial measure that is subject to the
                                                        disclosure requirements
pursuant to Item 10(e)(1) through (e)(3) of Regulation S-K, and
                                                        the Staff's Compliance
& Disclosure Interpretations ("C&DIs") on Non-GAAP Financial
 Sidney Chan
FirstName  LastNameSidney
ALR Technologies  SG Ltd. Chan
Comapany
May        NameALR Technologies SG Ltd.
     28, 2024
May 28,
Page 2 2024 Page 2
FirstName LastName
         Measures (updated December 13, 2022), Question No. 100.01. We note
your exclusion of
         share-based compensation results in presenting a non-GAAP performance
measure that
         excludes a normal and recurring operating expense. Please revise to
remove this non-
         GAAP financial measure, or tell us how your measure complies with the
guidance and if
         so, relabel the measure such to be loss before other items, as
adjusted. Alternatively, to the
         extent you intend to discuss the impact of the share-based
compensation on your financial
         results, please consider including a separate reconciliation table of
the amount of share-
         based compensation included in each of your operating expense line
items SG&A, product
         development and professional fees, and in the narrative discussion for
each, you may
         discuss the impact therein, without providing a non-GAAP financial
measure that
         excludes the share-based compensation. For example, we note your
discussion under
         SG&A expenses provides a discussion of SG&A expenses excluding
share-based
         compensation, which results in discussion of a non-GAAP financial
measure. Also, please
         clarify under Critical Accounting Estimates, Share-based Compensation,
on page 38 that
         you follow the guidance under ASC 718, as your current disclosure
indicates the
         superseded guidance of SFAS 123R.

Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 58

3.       Refer to the second paragraph and your conclusion that disclosure
controls and procedures
         ("DCP") were effective. However, we note that your assessment of
internal control over
         financial reporting ("ICFR") was not effective due to the material
weaknesses described
         therein. To the extent that ICFR has been determined to be not
effective due to
         the material weakness identified, we would expect your DCP also to be
not effective due
         to the substantial overlap of controls. Refer to SEC Release No.
33-8238, Section II.D.
         Please revise to ensure consistent conclusions for both DCP and ICFR
are presented.

Management's Report on Internal Control over Financial Reporting, page 59

4.       In the paragraphs where you refer to management, please expand to
disclose if your
         management includes the participation of your chief executive officer
and chief financial
         officer. In addition, under the heading of Changes in Internal Control
over Financial
         Reporting on page 60, please revise to disclose if there were any
change in your internal
         control over financial reporting ("ICFR") identified in connection
with your evaluation of
         ICFR, other than those discussed above relating to the material
weakness, that occurred
         during your fourth fiscal quarter (i.e., quarter ended December 31,
2023) that has
         materially affected, or is reasonably likely to materially affect,
your internal control
         over financial reporting. Refer to Item 308(c) of Regulation S-K and
to the requirements
         of paragraph 4(d) of the Exhibit 12 Certifications.

         In closing, we remind you that the company and its management are
responsible for the
 Sidney Chan
ALR Technologies SG Ltd.
May 28, 2024
Page 3

accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Beverly Singleton at 202-551-3328 or Melissa Gilmore at
202-551-3777
with any questions.



FirstName LastNameSidney Chan                             Sincerely,
Comapany NameALR Technologies SG Ltd.
                                                          Division of
Corporation Finance
May 28, 2024 Page 3                                       Office of
Manufacturing
FirstName LastName