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March 14, 2023
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
Draft Registration Statement on Form S-1
Submitted February 15, 2023
CIK No. 0001947210
Dear Michael Cribari:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1 filed February 15, 2023
Prospectus Summary, page 2
1.We note your response to comment 3.  However, your response focuses on which games
are most popular with your players, as opposed to your position in the industry.  Please
disclose the basis for statements that you provide one of the largest selection of games and
that you have industry-leading and market-leading customer retention, innovation and
content.  Please define the industry and the competitors you are using for purposes of
these statements.  For example, please indicate the category for which you have "one of
the largest selection of games."  Please also indicate your customer retention rate as
compared to the average customer retention rate in your industry.

 FirstName LastNameMichael Cribari
 Comapany NameHigh Roller Technologies, Inc.
 March 14, 2023 Page 2
 FirstName LastName
Michael Cribari
High Roller Technologies, Inc.
March 14, 2023
Page 2
Business, page 51
2.We note your response to comment 11. Please further revise to indicate the status of your
contemplated operations in Southeast Asia, including the status of application(s) for
required license(s) or approval(s), given your disclosure on page 43 that you expect to be
operational in Southeast Asian markets before the end of Q1 2023. Please specify where
in Southeast Asia you plan on operating.
Licenses, page 52
3.We note your response to comment 10 and reissue in part. Please revise your discussion
about the licenses and sublicenses obtained from the Curacao Gaming Authority as well as
the Estonian license held by Happy Hour Solutions to include the duration and expiration
date/renewal date of such licenses, and any material obligations under your domain
license agreement with Happy Hour Solutions. We also note that Ellmount Entertainment
is withdrawing from the Malta licensed activities and has not operated under its Malta
license since June 2022. Given this, please explain why you state elsewhere in the
prospectus that you maintain a license from Malta. Please also tell us if withdrawing from
Malta licensed activities will have a material impact on your financial results.
            You may 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 Jennie Beysolow at 202-551-8108 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Aaron A. Grunfeld, Esq.