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CORRESP
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June 11, 2024

Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

Washington, D.C. 20549

    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

To Whom It May Concern:

ALR Technologies SG Ltd. (“ALR”)
is submitting this letter in response to the comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter dated May 28, 2024 with respect to the above-referenced Annual Report on Form 20-F
(the “Form”).

ALR’s responses set forth
in this letter are numbered to correspond to the numbered comments in the Staff’s letter. All capitalized terms used but not defined
herein have the meanings assigned to such terms in the Forms. For ease of reference, we have set forth the Staff’s comments and
our responses below:

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.

ALR Response:

ALR proposes to amend the
Form 20-F by adding an introduction note to the table presentation of results of operations explaining that amounts presented have been
rounded to the nearest thousand and we will update the table to include negative brackets around amounts for line items of loss before
other items and net loss.

 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 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.

ALR Response:

 i) ALR
                                            proposes to amend Form 20-F to delete the section titled “Loss before Other Items and
                                            Share-based Compensation” and replace with the following “Share-based Compensation
                                            included in Net Loss

Share-based
Compensation included in Net Loss

A substantial amount of the net
loss is comprised of Share-based Compensation. Share based Compensation consists of:

 1) Incentive
                                            stock options granted to, or existing stock options modified to, incentivize- personnel as
                                            part of the compensation offered to attract and retain personnel. Share-based compensation
                                            expense as a result of these activities are included within product development fees, professional
                                            fees and selling, general and administrative expenses.

 2) From
                                            time-to-time, the Company issues and modifies warrants in connection with loans and lines
                                            of credit provided to the Company. Share-based Compensation expense as a result of these
                                            activities is included in interest expense.

Included in net loss is Share-based
Compensation expense as follows:

    Share based Compensation included in:
    2023
    2022
    2021

    Product development fees
      1,061,000
      227,000
      222,000

    Professional fees
      404,000
      39,000
      169,000

    Selling, general and administrative
      1,402,000
      1,499,000
      587,000

    Loss before other Items
      2,867,000
      1,765,000
      978,000

    Interest expense
      —
      4,005,000
      3,425,000

    Net Loss
      2,867,000
      5,770,000
      4,403,000

    Share based compensation expense as a percentage of Net Loss
      38 %
      54 %
      52 %

Furthermore, Share-based Compensation
expense included within product development fees, professional fees, and selling, general and administrative expenses represented the
following percentage of the loss before other items for fiscal years 2023, 2022 and 2021.

    2023
    2022
    2021

    Share based Compensation included in product development fees, professional fees, selling general and administrative expenses
      2,867,000
      1,765,000
      978,000

    Other expenses in product development fees, professional fees and selling, general and administrative expenses
      1,947,000
      2,504,000
      1,963,000

    Loss Before other Items
      4,818,000
      4,270,000
      2,946,000

    Share based compensation expense as a percentage of Loss Before other Items
      60 %
      41 %
      33 %

The Share-based Compensation highlighted
above is a non-cash recurring expense incurred by the Company which varies significantly year to year based on the option awards granted
and warrant activity issued related to financing requirements.

 ii) ALR
                                            proposes to amend the Form 20-F regarding the “Share-based
                                            Compensation” on Page 38 as follows:

We follow
the provisions of Accounting Standards Codification Topic 718 Stock Compensation
(“ASC 718”). ASC 718 requires companies to estimate the fair value of share-based payment awards on the date of grant
using an option pricing model. The value of the portion of the award that is ultimately expected to vest is recognized as an expense
over the requisite service period in the Company’s consolidated financial statements. The Company estimates the fair value of the
stock options using the Black-Scholes Option Pricing Model. The Black-Scholes Option Pricing Model requires the input of highly subjective
assumptions, including the option’s expected life and the price volatility of the underlying stock. The Company accounts for forfeitures
as they occur.

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.

ALR Response:

ALR proposes to amend Form
20-F in the second paragraph under Evaluation of Disclosure Controls as follows:

“As
required by SEC Rule 13a-15(b), we carried out an evaluation, under the supervision and with the participation of our management, including
our CEO and CFO, of the effectiveness of the design and operation of our disclosure controls and procedures as of the end of the period
covered by this Annual Report. Based upon that
evaluation, our management, including our CEO and CFO, has concluded that as of the end of the period covered by this Annual Report our
existing disclosure controls and procedures were ineffective due to the material weakness in internal control over financial
reporting identified below.”

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.

ALR Response:

 i) ALR
                                            proposes to amend Form 20-F under Management’s Report on Internal Control over Financial
                                            Reporting to expand disclosure to include our Chief Executive Officer and Chief Financial
                                            Officer in the applicable paragraphs.

 ii) ALR
                                            proposes to amend Form 20-F to replace the prior certifications attached as Exhibits 31.1,
                                            31.2, and 32.1, with new certifications on Exhibits 12.1, 12.2 and 13.1, complying with the
                                            requirements of Form 20-F. Specifically, the certifications contained in paragraph 4(d) of
                                            the Exhibit 12 certifications required by Form 20-F speak only to the annual period covered
                                            by the Form 20-F, which is the applicable reporting period, and eliminate the need to discuss
                                            any changes in ALR’s internal control over financial reporting during the fourth fiscal
                                            quarter separate from such annual reporting period.

If you have any questions related
to the foregoing, please contact Steve Brassard, Director, Finance and Accounting of ALR. Mr. Brassard can be reached by phone at (604)
603-7986.

Sincerely,

/s/ Sidney Chan

    Sidney Chan

    Chief Executive Officer and Chief
        Financial Officer

    ALR Technologies SG Ltd.