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                              March 14, 2023

       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.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted February
15, 2023
                                                            CIK No. 0001947210

       Dear Michael Cribari:

             We have reviewed your amended 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.

       Amendment No. 1 to Draft Registration Statement on Form S-1 filed
February 15, 2023

       Prospectus Summary, page 2

   1.                                                   We note your response
to comment 3. However, your response focuses on which games
                                                        are most popular with
your players, as opposed to your position in the industry. Please
                                                        disclose the basis for
statements that you provide one of the largest selection of games and
                                                        that you have
industry-leading and market-leading customer retention, innovation and
                                                        content. Please define
the industry and the competitors you are using for purposes of
                                                        these statements. For
example, please indicate the category for which you have "one of
                                                        the largest selection
of games." Please also indicate your customer retention rate as
                                                        compared to the average
customer retention rate in your industry.
 Michael Cribari
High Roller Technologies, Inc.
March 14, 2023
Page 2
Business, page 51

2.    We note your response to comment 11. Please further revise to indicate
the status of your
      contemplated operations in Southeast Asia, including the status of
application(s) for
      required license(s) or approval(s), given your disclosure on page 43 that
you expect to be
      operational in Southeast Asian markets before the end of Q1 2023. Please
specify where
      in Southeast Asia you plan on operating.
Licenses, page 52

3.    We note your response to comment 10 and reissue in part. Please revise
your discussion
      about the licenses and sublicenses obtained from the Curacao Gaming
Authority as well as
      the Estonian license held by Happy Hour Solutions to include the duration
and expiration
      date/renewal date of such licenses, and any material obligations under
your domain
      license agreement with Happy Hour Solutions. We also note that Ellmount
Entertainment
      is withdrawing from the Malta licensed activities and has not operated
under its Malta
      license since June 2022. Given this, please explain why you state
elsewhere in the
      prospectus that you maintain a license from Malta. Please also tell us if
withdrawing from
      Malta licensed activities will have a material impact on your financial
results.
       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
other
questions.



                                                           Sincerely,
FirstName LastNameMichael Cribari
                                                           Division of
Corporation Finance
Comapany NameHigh Roller Technologies, Inc.
                                                           Office of Trade &
Services
March 14, 2023 Page 2
cc:       Aaron A. Grunfeld, Esq.
FirstName LastName