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 May 28, 2025

Min-jie Cui
Chief Financial Officer
MKDWELL Tech Inc.
1F, No. 6-2, Duxing Road,
Hsinchu Science Park,
Hsinchu City 300, Taiwan

 Re: MKDWELL Tech Inc.
 Form 20-F for the Fiscal Year Ended December 31, 2024
 Filed April 3, 2025
 File No. 001-42197
Dear Min-jie Cui:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 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 20-F for the Fiscal Year Ended December 31, 2024
Item 3. Key Information
Risks Related to Doing Business in China, page 8

1. Please quantify any cash flows and transfers of other assets by type
that have occurred
 between the holding company and its subsidiaries and direction of
transfer. Quantify
 any dividends or distributions that a subsidiary has made to the holding
company and
 which entity made such transfer, and their tax consequences. Similarly
quantify
 dividends or distributions made to U.S. investors, the source, and their
tax
 consequences. Your disclosure should make clear if no transfers,
dividends, or
 distributions have been made to date.
Item 13. Defaults, Dividend Arrearages and Delinquencies, page 71

2. We note your disclosures of the amounts involving your financial leasing
contract
 dispute, the legal matter with the previous U.S. legal advisor of Cetus
Capital, and the
 May 28, 2025
Page 2

 amended satisfaction and discharge agreement. We also note your
disclosure on page
 F-35 that the amount related to the litigation matter with the previous
U.S. legal
 advisor of Cetus Capital was not able to be quantified, and no related
liability was
 accrued. Please tell us whether any of the other amounts have been
accrued as of the
 reported periods and how you complied with the disclosure requirements
of ASC 450-
 20-50 related to the three matters. Additionally, tell us your
consideration for
 disclosure on page 63 pursuant to the requirements for Item 8.A.7 of
Form 20-F.
Item 15. Controls and Procedures
Management's Annual Report on Internal Control over Financial Reporting, page
71

3. We note that you identified material weaknesses; however, you do not
include a
 statement as to whether your internal control over financial reporting
is effective as
 required by Item 15(b)(3) of Form 20-F. Please revise to include a
statement as to
 whether ICFR is effective in future filings. Also revise "significant
weaknesses"
 appropriately.
Item 16F. Change in Registrant's Certifying Accountant, page 73

4. We note your disclosure that the client-auditor relationship between the
Company and
 MKDWell Limited, a subsidiary of the Company, with Marcum Asia CPAs LLP
 ceased. Please revise to disclose whether the former accountant
resigned, declined to
 stand for re-election, or was dismissed. Refer to Item 16F(a)(1)(i) of
Form 20-F.
Exhibit 13.1, page X-13

5. Your Exhibit 13.1 certification references a name other than that of
your Chief
 Executive Officer in the first paragraph. Please revise the
certification in future filings
 accordingly.
 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 Stephany Yang at 202-551-3167 or Melissa Gilmore at
202-551-3777
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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