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                                January 31, 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.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed January 18,
2024
                                                            File No. 333-276176

       Dear Michael Cribari:

            We have reviewed your amended 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.
Unless we note otherwise,
       any references to prior comments are to comments in our January 5, 2024
letter.

       Form S-1 Amendment No. 1 filed January 18, 2024

       Risk Factors
       Our amended and restated certificate..., page 37

   1.                                                   The description of your
exclusive forum provision does not appear to match the exclusive
                                                        forum provision
contained in your amended and restated certificate of incorporation. For
                                                        example, your
disclosure indicates that the exclusive forum provision is limited to state
                                                        law claims, which is
not specified in your certificate of incorporation. In addition, the
                                                        actions covered by the
exclusive forum provision in the disclosure are not consistent with
                                                        those in your
certificate of incorporation. Further, your certificate of incorporation
                                                        designates an
alternative court if the Court of Chancery does not have jurisdiction
                                                        and indicates that the
federal district courts are, to the fullest extent permitted by law, the
                                                        sole and exclusive
forum for claims under the Securities Act of 1933, but this is not
                                                        explained in your
disclosure. Please advise and revise accordingly.
 Michael Cribari
High Roller Technologies, Inc.
January 31, 2024
Page 2
Use of Proceeds, page 39

2.    Please explain how you determined net proceeds would be $11,619,998.
Dilution, page 41

3.    It appears the net tangible book value as of September 30, 2023 equals
total stockholders'
      equity at September 30, 2023. Please tell us your consideration of
excluding any
      intangible assets that cannot be sold separately from all other assets of
the business and
      excluding any other intangible asset for which recovery of book value is
subject to
      significant uncertainty or illiquidity.
       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 31, 2024 Page 2
cc:       Aaron A. Grunfeld, Esq.
FirstName LastName