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May 28, 2024
Sidney Chan
Chief Executive Officer and Chief Financial Officer
ALR Technologies SG Ltd.
9 Raffles Place
#26-01 Republic Plaza
Singapore 048619
Re:ALR Technologies SG Ltd.
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2023
Filed April 30, 2024
File No. 000-56491
Dear Sidney Chan:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2023
Operating and Financial Review and Prospects
Results of Operations, page 29
1.Please provide an introduction note to the table presentation of results of operations
explaining that amounts presented have been rounded to the nearest thousand. Further,
consider including negative brackets around amounts for your line items of loss before
other items and net loss, similar to the presentation included in your consolidated
statements of operations on page F-5.

2.Refer to the discussion of Loss before Other Items and Share-based Compensation on
page 30. We note your computation and discussion of loss before other items and share-
based compensation appears to be a Non-GAAP financial measure that is subject to the
disclosure requirements pursuant to Item 10(e)(1) through (e)(3) of Regulation S-K, and
the Staff's Compliance & Disclosure Interpretations ("C&DIs") on Non-GAAP Financial

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Measures (updated December 13, 2022), Question No. 100.01. We note your exclusion of
share-based compensation results in presenting a non-GAAP performance measure that
excludes a normal and recurring operating expense. Please revise to remove this non-
GAAP financial measure, or tell us how your measure complies with the guidance and if
so, relabel the measure such to be loss before other items, as adjusted. Alternatively, to the
extent you intend to discuss the impact of the share-based compensation on your financial
results, please consider including a separate reconciliation table of the amount of share-
based compensation included in each of your operating expense line items SG&A, product
development and professional fees, and in the narrative discussion for each, you may
discuss the impact therein, without providing a non-GAAP financial measure that
excludes the share-based compensation. For example, we note your discussion under
SG&A expenses provides a discussion of SG&A expenses excluding share-based
compensation, which results in discussion of a non-GAAP financial measure. Also, please
clarify under Critical Accounting Estimates, Share-based Compensation, on page 38 that
you follow the guidance under ASC 718, as your current disclosure indicates the
superseded guidance of SFAS 123R.

Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 58
3.Refer to the second paragraph and your conclusion that disclosure controls and procedures
("DCP") were effective. However, we note that your assessment of internal control over
financial reporting ("ICFR") was not effective due to the material weaknesses described
therein. To the extent that ICFR has been determined to be not effective due to
the material weakness identified, we would expect your DCP also to be not effective due
to the substantial overlap of controls. Refer to SEC Release No. 33-8238, Section II.D.
Please revise to ensure consistent conclusions for both DCP and ICFR are presented.

Management's Report on Internal Control over Financial Reporting, page 59
4.In the paragraphs where you refer to management, please expand to disclose if your
management includes the participation of your chief executive officer and chief financial
officer. In addition, under the heading of Changes in Internal Control over Financial
Reporting on page 60, please revise to disclose if there were any change in your internal
control over financial reporting ("ICFR") identified in connection with your evaluation of
ICFR, other than those discussed above relating to the material weakness, that occurred
during your fourth fiscal quarter (i.e., quarter ended December 31, 2023) that has
materially affected, or is reasonably likely to materially affect, your internal control
over financial reporting. Refer to Item 308(c) of Regulation S-K and to the requirements
of paragraph 4(d) of the Exhibit 12 Certifications.

            In closing, we remind you that the company and its management are responsible for the

 FirstName LastNameSidney Chan
 Comapany NameALR Technologies SG Ltd.
 May 28, 2024 Page 3
 FirstName LastName
Sidney Chan
ALR Technologies SG Ltd.
May 28, 2024
Page 3
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Beverly Singleton at 202-551-3328 or Melissa Gilmore at 202-551-3777
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing