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                             December 20, 2022

       Michael Cribari
       Chief Executive Officer
       High Roller Technologies, Inc.
       400 South 4th Street, Suite 500-#390
       Las Vegas, Nevada 89101

                                                        Re: High Roller
Technologies, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted November
23, 2022
                                                            CIK No. 0001947210

       Dear Michael Cribari:

              We have reviewed your draft registration 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1 filed November 23, 2022

       Our Business Model, page 2

   1.                                                   Please revise to expand
your discussion about your association with Spike Up Media.
                                                        Please explain why you
believe that your association with Spike Up Media provides cost-
                                                        effective lead
generation which results in gross operating margins for Highroller.com that
                                                        are higher than those
[you] experienced with CasinoRoom.com.
 Michael Cribari
FirstName
High RollerLastNameMichael
            Technologies, Inc.Cribari
Comapany20,
December   NameHigh
              2022 Roller Technologies, Inc.
December
Page 2    20, 2022 Page 2
FirstName LastName
Our Competitive Strengths, page 2

2.       Please revise to list the remote licensed markets (Offshore) where you
may legally operate
         using international licenses, as well as the locally licensed markets
(Onshore) where you
         operate. In addition, where you state that licenses provide you with
"broad European
         player access" please indicate the particular countries in Europe
where you operate.
Prospectus Summary
Market Trends, page 2

3.       We note statements such as the following:

                We provide one of the largest selections of games from the
leading providers...
                We have an industry-leading community platform...

         Please revise to disclose the basis for these statements. For example,
please indicate the
         basis on which you determined that you have an "industry-leading"
platform, and please
         disclose how your selections of games compares to the "leading
providers," and indicate
         how you are defining "leading providers."
Corporate Information, page 5

4.       Please revise to better explain the current corporate structure.
Consider including a chart
         to depict the corporate structure and illustrate any material
relationships, with a more
         detailed discussion in your Business section.
Risks Related to our Third-Party Vendor Relationships, page 31

5.       Please identify any material third-party relationships where
termination of the agreement
         could have an adverse effect on the company. In addition, if you are
substantially
         dependent upon these relationships to conduct your business, please
file contracts you
         have with such third party provider(s) as an exhibit. Refer to Item
601(b)(10) of
         Regulation S-K.
Management   s Discussion And Analysis Of Financial Condition And Results Of
Operations
Going Concern, page 45

6.       Please revise your Prospectus Summary and Risk Factors section to
highlight the auditor's
         explanatory paragraph regarding your ability to continue as a going
concern.
Liquidity and Capital Resources, page 47

7.       Please revise to disclose here as you do in the Use of Proceeds
section that you believe
         your existing cash and revenue together with the net proceeds from
this offering will be
         sufficient to fund your operations and capital expenditure
requirements for the next 18-24
         months.
 Michael Cribari
High Roller Technologies, Inc.
December 20, 2022
Page 3
Principal Shareholders, page 49

8.       Please revise to disclose the natural person or persons who have
voting and dispositive
         control of the shares held by OEH Invest AB.
Business, page 52

9.       Please revise to describe the "out-sourcing of resource demanding
components" which
         you state yields a highly competitive cost model and differentiates
your brand.
10.      Please disclose all material information about the licenses you
currently hold in Malta and
         Curacao, as well as information on the license held by the Estonian
licensee, including the
         duration and expiration date of such licenses, and any material
obligations under such
         licenses. Please file the license agreement with your Estonian
licensee, which appears to
         be Happy Hour, as an exhibit to the registration statement, and
disclose the material terms
         of the agreement.
11.      You note that you are planning to enter the United States, Latin
American and Asian
         markets in 2023 and 2024, once the respective states and countries
regulate and legalize
         online casinos. Please expand upon these plans and why you anticipate
that these markets
         will legalize online casinos in 2023 and 2024, and to the extent that
online casinos are
         already legal, please explain when you plan to enter the market as it
does not appear that it
         would be contingent on such legalization. Explain the risk to your
business and your
         expansion plans if these markets do not legalize online casinos.
Please also tell us why
         you include market statistics on page 56 for the African gambling
market, as you do not
         appear to have plans to enter this market.
Strategic Positioning, page 57

12.      Please explain how your in-house technology is "state of the art."
Please revise to describe
         the Unique Selling Propositions which you state on page 58 make your
business stand out
         from the competition and are within social, community and streaming
based product
         features that lend well to viral, affiliate and social marketing.
Management, page 61

13.      For each director, briefly discuss the specific experience,
qualifications, attributes or skills
         that led to the conclusion that the person should serve as a director.
Refer to Item
         401(e)(1) of Regulation S-K.
Executive
FirstNameCompensation,
            LastNameMichael pageCribari
                                  66
Comapany
14.         NameHigh
       Please           Roller
              file a copy  of theTechnologies,
                                  employment Inc.
                                                agreements referenced in this
section as exhibits to
       the registration
December   20, 2022 Pagestatement.
                           3         Refer to Item 601(b)(10)(iii)(A) of
Regulation S-K.
FirstName LastName
 Michael Cribari
FirstName
High RollerLastNameMichael
            Technologies, Inc.Cribari
Comapany20,
December   NameHigh
              2022 Roller Technologies, Inc.
December
Page 4    20, 2022 Page 4
FirstName LastName
Certain Relationships And Related Party Transactions, page 70

15.      Please revise this section to disclose the related person(s) involved
in the transactions
         discussed in this section. For example, please indicate the related
person(s) who have
         interests or ownership in the entities (Spike Up Media, Ellmount
Interactive AB, Happy
         Hour Solutions, WKND, etc.) such that the transactions are related
party transactions that
         must be disclosed under Item 404(d) of Regulation S-K.
16.      To the extent not already filed, please file any instruments governing
the transactions
         discussed in this section or tell us why you do not believe you are
required to do so. See
         Item 601(b)(4) of Regulation S-K.
General

17.      Please provide us with supplemental copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         have presented or expect to present to potential investors in reliance
on Section 5(d) of the
         Securities Act, whether or not you retained, or intend to retain,
copies of those
         communications. Please contact the staff member associated with the
review of this filing
         to discuss how to submit the materials, if any, to us for our review.
       You may contact Scott Stringer at 202-551-3272 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennie Beysolow at 202-551-8108 or Erin Jaskot at 202-551-3442 with any
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
cc:      Aaron A. Grunfeld, Esq.