October 4, 2024

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. 7 to Registration Statement on Form S-1
           Filed September 19, 2024
           File No. 333-276176
Dear Michael Cribari:

     We have reviewed your amended registration statement and have the
following
comment(s).

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments. Unless we
note otherwise,
any references to prior comments are to comments in our June 17, 2024 letter.

Amendment No. 7 to Registration Statement on Form S-1
Management's Discussion and Analysis of Financial Condition and Results of
Operaitons
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.
 October 4, 2024
Page 2

       Please 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 Jenna Hough at 202-551-3063 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.