July 26, 2024

Douglas Murphy-Chutorian
Chief Executive Officer
Semler Scientific, Inc.
2340-2348 Walsh Avenue, Suite 2344
Santa Clara, CA 95051

       Re: Semler Scientific, Inc.
           Amendment No. 1 to Registration Statement on Form S-3
           Filed July 11, 2024
           File No. 333-280013
Dear Douglas Murphy-Chutorian:

     We have reviewed your amended registration statement and have the
following
comments.

       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 July 2, 2024 letter.

Amendment No. 1 to Registration Statement on Form S-3
Bitcoin Strategy, page 9

1.     Refer to your responses to prior comments 9 and 10. Please identify your
liquidity
       providers. Additionally, you state you executed bitcoin trades using a
time-weighted
       average price over a pre-arranged time period. With respect to future
bitcoin purchases:

             Describe the material aspects of methodology used to calculate the
time-weighted
           average price of bitcoin.
             Disclose the pre-arranged time periods for the transfers of
bitcoin and describe how
           the bitcoin is transferred.
             To the extent that the average price is calculated by referencing
crypto asset trading
           platforms, identify the trading platforms, where each trading
platform is located and
           how it is licensed or regulated, and the criteria and process for
selecting particular
 July 26, 2024
Page 2

           trading platforms.
2.     Refer to your response to prior comment 11. Please identify the
third-party custodians and
       file the custody agreements as exhibits to the registration statement.
Also disclose and
       discuss the material aspects of the bitcoin custody agreements,
including the following:

             Describe how the custodian stores the private keys, including
whether they will be
           commingled with assets of other customers and the geographic area
where they will
           be stored.
             Identify who will have access to the private key information and
disclose whether any
           entity will be responsible for verifying the existence of the
bitcoin.
             Disclose whether the custodian carries insurance for any losses of
the bitcoin it
           custodies for you. If so, quantify the amount of and character of
the insurance,
           disclose whether the insurance is shared among the custodian   s
customers, and
           describe any limitations on the custodian   s liability.
3.     Refer to your response to comment 14. Please describe the AML, KYC and
other
       procedures conducted by you, your liquidity providers, and your
custodians, including
       whether a transaction counterparty is subject to sanctions and is
otherwise in compliance
       with applicable laws and regulations.
       Please contact Benjamin Richie at 202-551-7857 or Lauren Nguyen at
202-551-3642
with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Marianne Sarrazin, Esq.