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                              February 3, 2024

       Jin Kuang
       Chief Financial Officer
       VoIP-Pal.Com Inc.
       7215 Bosque Boulevard, Suite 102
       Waco, TX 76710-4020

                                                        Re: VoIP-Pal.Com Inc.
                                                            Form 10-K for the
Fiscal Year Ended September 30, 2023
                                                            File No. 000-55613

       Dear Jin Kuang:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment(s).

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended September 30, 2023

       Controls and Procedures, page 34

   1.                                                   Refer to your
discussion under Evaluation of Disclosure Controls and Procedures and
                                                        consider revising to
first include a discussion of your disclosure controls and procedures
                                                        to address the
following and/or provide similar disclosures. Refer to Item 307 of
                                                        Regulation S-K.

                                                              State whether as
of the end of the period covered by this report, your principal
                                                            executive officer
and principal financial officer evaluated the effectiveness of your
                                                            disclosure controls
and procedures (as defined in Rule 13a-15(e) and 15d-15(e) of the
                                                            Exchange Act).

                                                              Also state if
your disclosure controls and procedures are controls and other
                                                            procedures that are
designed to ensure that information required to be disclosed in
                                                            your reports filed
or submitted under the Exchange Act are recorded, processed,
                                                            summarized and
reported, within the time periods specified in the SEC   s rules and
                                                            forms.
 Jin Kuang
FirstName LastNameJin Kuang
VoIP-Pal.Com  Inc.
Comapany3,NameVoIP-Pal.Com
February   2024             Inc.
February
Page 2 3, 2024 Page 2
FirstName LastName


                Further state if your disclosure controls and procedures
include, without limitation,
              controls and procedures designed to ensure that information
required to be disclosed
              in your reports filed under the Exchange Act is accumulated and
communicated to
              management, including your Chief Executive Officer and Chief
Financial Officer, to
              allow timely decisions regarding required disclosure.

                We note you have concluded that your disclosure controls and
procedures are
              effective at the reasonable assurance level. As you have
identified material
              weaknesses in your internal control over financial reporting,
please consider revising
              your conclusion on disclosure controls and procedures to instead
state that your
              principal executive officer and principal financial officer
concluded that your
              disclosure controls and procedures were not effective as of
September 30, 2023 (the
              end of the year covered by this Annual Report) due to the
material weaknesses in
              internal control over financial reporting described below. In
this regard, because of
              the substantial overlap between disclosure controls and
procedures and that of
              internal control over financial reporting, we would anticipate
that both would be
              concluded as not effective. Please revise.

2.       Please also address the following with respect to your disclosures on
the evaluation of
         internal control over financial reporting:

                Provide a sub-heading such as Management's Report on Internal
Control Over
              Financial Report and provide a statement of management's
responsibility for
              establishing and maintaining adequate internal control over
financial reporting. Refer
              to Item 308(a)(1) of Regulation S-K. Please continue to include
all of your content
              about the material weaknesses and related disclosures under this
subheading.

                Provide a definitive conclusion that your management, including
the principal
              executive officer and principal financial officer, have concluded
as of the end of the
              fiscal year covered by this Annual Report on Form 10-K that your
internal control
              over financial reporting was not effective due to the material
weaknesses identified
              below. We note you instead concluded that it was not completely
efficient. Please
              revise accordingly. Refer to Item 308(a)(3) of Regulation S-K.


       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Beverly Singleton at 202-551-3328 or Kevin Woody at
202-551-3629 with
any questions.
 Jin Kuang
VoIP-Pal.Com Inc.
February 3, 2024
Page 3


FirstName LastNameJin Kuang      Sincerely,
Comapany NameVoIP-Pal.Com Inc.
                                 Division of Corporation Finance
February 3, 2024 Page 3          Office of Manufacturing
FirstName LastName