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                              February 13, 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
                                                            Response dated
February 9, 2024
                                                            File No. 000-55613

       Dear Jin Kuang:

              We have reviewed your February 9, 2024 response to our comment
letter 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. Unless
       we note otherwise, any references to prior comments are to comments in
our February 3, 2024
       letter.

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

       Controls and Procedures, page 34

   1.                                                   We have reviewed your
response to our prior comment 1, along with the proposed
                                                        revisions attached
thereto. With respect to the response addressing the third bullet, please
                                                        ensure your disclosure
includes references to both the Chief Executive Officer and Chief
                                                        Financial Officer, as
we note your proposed disclosure only refers to the Chief Executive
                                                        Officer. Further,
consider moving this same paragraph disclosure (i.e., "Disclosures
                                                        controls and procedures
are controls and other procedures that are designed to ensure that
                                                        information required to
be disclosed in our reports filed or submitted...is accumulated and
                                                        communicated to
management, including our Chief Executive Officer, to allow timely
                                                        decisions regarding
required disclosure.") to placement under the section of "Evaluation
                                                        of Disclosure Controls
and Procedures," rather than including it under the section
                                                        of "Evaluation of
Effectiveness of ICFR."
 Jin Kuang
VoIP-Pal.Com Inc.
February 13, 2024
Page 2


2.       Refer to the attachment with your response and address the following:

                In the first paragraph under the heading, "Management   s
Report on Internal Control
              over Financial Reporting," refer to the second and third
sentences. As your
              September 30, 2023 audited financial statements have been
prepared under U.S.
              GAAP, please omit references to IFRS, as issued by the
International Accounting
              Standards Board.

                Refer to the section "Changes in Internal Control Over
Financial Reporting." Please
              revise to clarify, if true, there have been no changes in your
internal controls over
              financial reporting during the fourth quarter ended September 30,
2023 that have
              materially affected or are reasonably likely to materially affect
such controls. Your
              current disclosure refers to the year ended September 30, 2023,
rather than the fourth
              fiscal quarter. Refer to Item 308(c) of Regulation S-K.


       Please contact Beverly Singleton at 202-551-3328 or Kevin Woody at
202-551-3629 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameJin Kuang                                    Sincerely,
Comapany NameVoIP-Pal.Com Inc.
                                                               Division of
Corporation Finance
February 13, 2024 Page 2                                       Office of
Manufacturing
FirstName LastName