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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.

 FirstName LastNameJin  Kuang
 Comapany NameVoIP-Pal.Com Inc.
 February 3, 2024 Page 2
 FirstName LastNameJin  Kuang
VoIP-Pal.Com Inc.
February 3, 2024
Page 2

•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.

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