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                              January 5, 2024

       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.
                                                            Registration
Statement on Form S-1
                                                            Filed December 20,
2023
                                                            File No. 333-276176

       Dear Michael Cribari:

                                                        We have reviewed your
registration statement and have the following comment(s).

              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.

       Form S-1 filed December 20, 2023

       Risk Factors, page 8

   1.                                                   We note the exclusive
forum provision in Article TWELFTH of Exhibit 3.1 and that the
                                                        Court of Chancery of
the State of Delaware is the exclusive forum for certain litigation,
                                                        including any
"derivative action." Please describe this provision in an appropriate section
                                                        of the prospectus,
including the applicability of this provision to the Securities Act and
                                                        Exchange Act. Please
add risk factor disclosure to describe any risks or other impacts of
                                                        the provision on
investors, such as increased costs to bring a claim and that these
                                                        provisions can
discourage claims or limit investors' ability to bring a claim in a judicial
                                                        form that they find
favorable, and address any uncertainty about enforceability.
       Managements Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, Interest expense, net, page 49

   2.                                                   We note the increase in
interest expense, net is linked to non cash interest expense related
                                                        to lease obligations.
Please explain the amount and nature of your non cash interest
 Michael Cribari
High Roller Technologies, Inc.
January 5, 2024
Page 2
       expense and differentiate it from non cash lease expense noted on your
Statements of
       Cash Flows. Please provide any relevant accounting literature that
supports your response.
Licenses, page 55

3.     We note that the Domain License Agreement filed as Exhibit 10.14 remains
in force until
       December 31, 2022 but may be extended. Please disclose the current
termination date in
       the prospectus. To the extent you have extended the term of the
agreement, please file the
       extension agreement as an exhibit.
General

4.     We note your response to comment 7 and reissue in part. You disclose the
soft launch of
       your second brand, Fruta.com. However, you did not revise your
disclosures under
       Management's Discussion and Analysis to address the impact of the launch
or other
       commitments or uncertainties this launch or any future planned launch
has had, or may
       have, on your financial condition, operations, liquidity, or capital
position. Please revise to
       include this disclosure or in the alternative please indicate that you
do not believe this
       launch, or planned launches, have a material impact that requires
disclosure.
        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.

       Please 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 Jenna Hough at 202-551-3063 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
January 5, 2024 Page 2
cc:       Aaron A. Grunfeld, Esq.
FirstName LastName