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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."

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