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High Roller Technologies, Inc.

400 South 4th Street, Suite 500-#390

Las Vegas, Nevada 89101

(702) 509-524

By Electronic Mail Only

October 7, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

Attention: Jenna Hough

 Re: High Roller Technologies, Inc.

Amendment No. 8 to Registration Statement on Form S-1

Submitted October 7, 2024

File No. 333-276176

Dear Ms. Hough:

High Roller Technologies,
Inc. (the “Company,” “we,” “us” or “our”) hereby submits
this letter in response to comments from staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”), contained in its letter dated October 4, 2024 (the “Comment Letter”), relating
to Amendment No. 7 to Registration Statement on Form S-1, File No. 333-276176, filed with the Commission on September 19, 2024.
We are concurrently submitting via EDGAR Amendment No. 8 to the Registration Statement (“Amendment No. 8”).

For your
convenience, the paragraphs below include the captions used in the Comment Letter. Our response immediately follows the
Commission’s comment, including a page reference to the location of any changes made in Amendment No. 8 in
response to the Staff’s comments. Defined terms used but not otherwise defined herein have the meanings ascribed to
those terms in Amendment No. 8.

Amendment No. 7 to Registration Statement on Form S-1

Management’s Discussion and Analysis of Financial Condition
and Results of Operations

Results of Operations, page 46

    1.

        You indicate that revenue decreased
        by 17% for the six months ended June 30, 2024 as compared to the six months ended June 30, 2023 due primarily to your exit of a
        market due to a change in the regulatory environment. Please revise to name the market you exited. We further note that revenue
        for this period decreased in every country or region listed, with the exception of Finland. Please revise your disclosure to indicate
        the reason for the decrease in these regions and whether you believe this decrease is a trend you

        expect to continue in future financial
        periods. Add related risk factor disclosure, as appropriate.

RESPONSE: We have revised our disclosures on page 47 to indicate that we have exited Hungary and further
provided reasons for changes to our revenue in several countries. The
Company respectfully advises the Staff that it believes the existing risk factor discussion of regulatory changes and potential
fluctuations in its results of operations adequately describes the trends affecting the period-to-period differences noted by the
Staff.  Please see the relevant discussion in the “Risks Related to Government Regulation” subsection of Risk
Factors, pages 19-22 and the first risk factor appearing in the "General Risk Factors," on page 36.

Division of Corporation Finance

United States Securities and Exchange Commission

October 7, 2024

Page 2 of 2

We thank the Staff
in advance for its review of the foregoing and of Amendment No. 8. If you have further comments, we ask that you forward them by
electronic mail to our counsel, Aaron A. Grunfeld Esq. at agrunfeld@grunfeldlaw.com or by telephone at (310) 788-7577.

Very truly yours,

/s/ Ben Clemes

Chief Executive Officer