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    TroyGould
                                         pc

        1801
        Century Park East, 16th Floor

        Los
        Angeles, California 90067-2367

        Tel
        (310) 553-4441 | Fax (310) 201-4746

        www.troygould.com

                                                   Darren
                                         Freedman ● (310) 789-1207 ● dfreedman@troygould.com

    File
    No. 03072-0001

    June
    4, 2019

VIA
 EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Office of Manufacturing and Construction

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Sigma
                                         Labs, Inc.

        Form
        10-K for Fiscal Year Ended December 31, 2018

        Filed
        April 1, 2019

        Form
        10-Q for Fiscal Quarter Ended March 31, 2019

        Filed
        May 15, 2019

        File
        No. 001-38015

Ladies
and Gentlemen:

By
letter dated May 23, 2019, the staff (the “Staff”) of the Division of Corporation Finance of the Securities
and Exchange Commission (the “Commission”) provided Sigma Labs, Inc. (the “Company”) with
comments on the Company’s above-referenced Form 10-K and Form 10-Q.

This
letter sets forth responses of the Company to the Staff’s comments. The numbered responses and the headings set forth below
correspond to the numbered comments and headings in the Staff’s letter dated May 23, 2019.

                                                                       Securities
                                         and Exchange Commission

        June
        4, 2019

        Page
        2

Form
10-K for Fiscal Year Ended December 31, 2018

Intellectual
Property, page 14

    1.
    Please
    disclose the duration of the patents in your intellectual property portfolio. Please see Item 101(h)(4)(vii) of Regulation
    S-K.

COMPANY’S
RESPONSE:

The
duration of the patents in the Company’s intellectual property portfolio is as follows:

    Title
    Type
    Patent
    No.
    Expiration

 Date

    Duration

 in
                                         Years

 at
                                         5/31/2019

    Controlled
    Weld Pool Volume Control of Welding Processes
    US
    Utility
    8,354,608
    3/16/2031
    11.80

    Structurally
    Sound Reactive Materials
    US
    Utility
    8,372,224
    10/15/2030
    11.38

    Composite
    Projectile
    US
    Utility
    8,359,979
    3/21/2027
    7.81

    Methods
    and Systems for Monitoring Additive Manufacturing Processes
    US
    Utility
    9,999,924
    5/11/2036
    16.96

    Systems
    and Methods for Additive Manufacturing Operations
    US
    Utility
    10,207,489
    6/20/2037
    18.07

    Material
    Qualification System and Methodology
    US
    Utility
    10,226,817
    4/26/2037
    17.92

The
Company will disclose the duration of the patents in the Company’s intellectual property portfolio in its Annual Report
on Form 10-K for the fiscal year ended December 31, 2019.

Item
5. Market For Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities, page 25

    2.
    Please
    expand your disclosure of market information to include the range of high and low bid information of your registered common
    stock for each full quarterly period over the last two fiscal years. Please see Item 201(a)(iii) of Regulation S-K.

COMPANY’S
RESPONSE:

Since
February 15, 2017, the Company’s common stock has been listed and traded on a daily basis on The NASDAQ Capital Market under
the symbol “SGLB.” Pursuant to the Commission’s Release No. 33-10532 (August 17, 2018), Item 201(a) of Regulation
S-K was amended to eliminate the detailed disclosure requirement of historical high and low bid prices for an issuer whose common
stock is traded on an established public trading market. Therefore, we respectfully do not believe that the Company is required
to include this information.

                                                                       Securities
                                         and Exchange Commission

        June
        4, 2019

        Page
        3

Form
10-Q for Fiscal Quarter Ended March 31, 2019

Note
4 - Stockholders’ Equity

Deferred Compensation, page 9

    3.
    Please
    provide us with a better understanding of the nature, terms, and recipients of the shares of common stock issued with restrictions
    that generated $78,000 in compensation expense for the first quarter of fiscal year 2019 and a prepaid asset of $225,000 as
    of March 31, 2019. In addition, please provide us with your analysis of your accounting for these transactions, including
    the specific reference to the authoritative literature.

COMPANY’S
RESPONSE:

On
January 1, 2019, the Company issued 50,000 shares of common stock subject to restrictions, pursuant to the Company’s 2013
Equity Incentive Plan (the “2013 Plan”), to each of the Company’s four non-employee directors, valued at the
closing price of the Company’s common stock on December 31, 2018, which was $1.50 per share, or $300,000 in total. Such
shares are to vest ratably over four quarterly installments, subject in each case to the applicable director’s continuing
service as a director. During the three months ended March 31, 2019, the fair value of the shares that vested, $75,000, was expensed
as compensation and recorded as a reduction of prepaid board of directors compensation.

On
March 7, 2019, the Company issued 1,500 shares of common stock, pursuant to the 2013 Plan, to the Company’s Vice President
of Business Development, valued at the closing price of the Company’s common stock on the date of issuance of $2.00 per
share, or $3,000 in total, in connection with his achievement of performance milestones under Amendment No. 2, dated February
21, 2018, to his employment offer letter agreement, effective August 10, 2015. Such shares vested and were expensed immediately.

The
200,000 shares of common stock issued to directors were accounted for as follows:

    Upon
    Grant and Issuance – 01/01/2019:

    Prepaid
    Board of Directors Compensation
    $ 300,000

    Common
    Stock
    $ (200 )

    Additional
    Paid-in-Capital
    $ (299,800 )

    Each
    of January, February and March:

    Stock-Based
    Compensation
    $ 25,000

    Prepaid
    Board of Directors Compensation
    $ (25,000 )

                                                                       Securities
                                         and Exchange Commission

        June
        4, 2019

        Page
        4

The
1,500 shares of common stock issued to the Company’s Vice President of Business Development were accounted for as follows:

    Upon
    Grant and Issuance – 03/07/2019:

    Compensation
    Expense
    $ 3,000

    Common
    Stock
    $ (1.50 )

    Additional
    Paid-in-Capital
    $ (2,998.50 )

The
transactions were accounted for in accordance with ASC 718 Compensation – Stock Compensation, using the fair-value based
method to measure compensation cost and recognizing that cost over the service period, which is the same as the vesting period
in this case.

The Company will include
additional information in its Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2019 regarding the
nature, terms, and recipients of the shares of common stock issued with restrictions that generated $78,000 in compensation expense
for the first quarter of fiscal year 2019 and a prepaid asset of $225,000 as of March 31, 2019, in an effort to provide a better
understanding consistent with the Staff’s comment.

Please
advise the undersigned if you desire to receive any additional information in connection with your letter dated May 23, 2019.

    Very
    truly yours,

    TROYGOULD
    PC

    /s/
    Darren Freedman

    Darren
    Freedman