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    MKDWELL
                                            Tech Inc.

    1F,
    No. 6-2, Duxing Road,

    Hsinchu
    Science Park,

    Hsinchu
City 300, Taiwan

    Cetus
                                            Capital Acquisition Corp.

    Floor
    3, No. 6, Lane 99

    Zhengda
    Second Street, Wenshan District

    11602
Taipei, Taiwan, R.O.C.

Date:
May 28, 2024

Via
EDGAR

Division
of Corporation Finance

Office
of Energy & Transportation

Securities
and Exchange Commission

Washington,
D.C. 20549

    Attn.:
    Eiko
                                            Yaoita Pyles

    Anne
    McConnell

    Jenny
    O’Shanick

    Evan
    Ewing

    Re:
    MKDWELL
    Tech Inc.

    Amendment
                                            No. 2 to Registration Statement on Form F-4

    Filed
    May 2, 2024

    File
    No. 333-277785

Ladies
and Gentlemen:

MKDWELL
Tech Inc., a British Virgin Islands business company (the “Company”), together with Cetus Capital Acquisition Corp.
(“Cetus Capital”), hereby submits to the staff (the “Staff”) of the Securities and Exchanges Commission
(the “Commission”) this letter setting forth responses to the comments contained in the Staff’s letter dated
May 15, 2024 on the Company’s Registration Statement on Form F-4 previously filed on May 2, 2024.

Concurrently
with the submission of this letter, the Company is filing its revised registration statement on Form F-4 (the “Revised Registration
Statement”) publicly with the Commission.

The
Staff’s comments are repeated below in bold and are followed by our responses. We have included page references in the Revised
Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Revised Registration Statement.

Amendment
No. 2 to Registration Statement on Form F-4

Proposal
No. 1 The Business Combination Proposal

Summary
of MKD Taiwan Financial Analysis and Cetus Capital Internal Valuation Discussion September 2023 Projections, page 89

    1.
    Please
    revise to confirm whether the September 2023 projections still reflect management’s views on future performance and/or describe
    what consideration the board gave to obtaining updated projections or a lack of reliance upon the projections.

Response:
The Company and Cetus Capital respectfully submit that the “March 2023 Projections” were prepared in March 2023, on the basis
of which the equity valuation of MKD was agreed upon between Cetus Capital and MKD. This formed the basis of the Aggregate Merger Consideration
of $230,000,000 in the Business Combination Agreement which was entered into on June 20, 2023. Subsequently, prior to the submission
to the Commission of the first draft registration statement on Form F-4, Cetus Capital and MKD updated the projections and prepared the
projections titled “September 2023 Projections.” The “September 2023 Projections” were prepared and finalized
in September 2023 with a view to completing the Business Combination as soon as possible, but subject to the Commission’s review
of the Form F-4 registration statement. As at the date of this letter, Cetus Capital and MKD have included the financial results of both
Cetus Capital and MKD BVI for the financial year ended December 31, 2023 in the Revised Registration Statement.

Cetus
Capital’s management and board of directors confirm that the September 2023 Projections (financial forecasts for FY2024-FY2027)
still reflect their views on future performance, and thus that they believe that such projections can still be relied upon and that it
is not necessary to obtain updated projections at this time.

Please
refer to the revised disclosures in the section “September 2023 Projections”, which provides further details regarding the
foregoing determinations.

Please
also refer to the revised disclosures titled “Risk Factors—The Combined Company’s operating and financial results projections
relies in large part upon assumptions and analyses performed by Cetus Capital and MKD. If these assumptions or analyses prove to be incorrect,
the Combined Company’s actual operating results may be materially different from forecasted results.”

Management’s
Discussion and Analysis of Financial Condition and Results of Operations of MKD

Major
Factors Affecting Our Results of Operations, page 121

    2.
    We
    note that you removed disclosures related to your supply chain and demand for camper vans, which were added in response to prior
    comments. Please advise or revise.

Response:
Please refer to the revised section “Major Factors Affecting Our Results of Operations.”

Unaudited
Pro Forma Condensed Combined Financial Information, page 143

    3.
    Your
    disclosure, under the heading “Assuming the NTA Amendment Proposal is not approved and holders of 1,409,540 Cetus Capital Public
    Shares exercise their redemption rights” on page 144, states that $5,000,001 will be left in the trust account under
    scenario 2; however, your disclosures elsewhere in the filing state that this scenario will leave a minimum of $5,000,001 of net
    tangible assets, including the cash to be released from the Trust Account. Please correct this inconsistency. This comment is
    also applicable to disclosures on pages 7 and 15 that refer to $5,00,001 being left in the trust account.

Response:
Please refer to the revised disclosures in the Revised Registration Statement.

Pro
Forma Combined Condensed Statement of Operations, page 146

    4.
    Please
    correct the inconsistencies in the historical weighted average share and loss per share disclosures for MKD BVI on pages 146 and
    25 to correspond to amounts presented in the audited financial statements on page F-24.

Response:
Please refer to the revised disclosures in the Revised Registration Statement.

Note
3 - Adjustments to Unaudited Pro Forma Condensed Combined Financial Information

Adjustments
to Unaudited Pro Forma Condensed Combined Balance Sheet, page 148

    5.
    Your
    disclosure states that adjustment (4) reflects the contribution of all the share capital in MKD BVI to Cetus Capital; however, your
    disclosures elsewhere in the filing indicate that both MKD BVI shares and Cetus Capital shares will be exchanged for PubCo shares
    at Closing, and that MKD BVI and Cetus Capital will become wholly-owned subsidiaries of PubCo. Please correct this inconsistency.

Response:
Please refer to the revised disclosures in the Revised Registration Statement.

Index
to Financial Statements, page F-1

    6.
    Please
    provide updated interim financial statements and related financial disclosures for Cetus Capital throughout the filing, including
    MD&A, to the extent required by Rule 8-08 of Regulation S-X.

Response:
Please refer to the revised disclosures in the Revised Registration Statement.

If
you have any questions regarding the Revised Registration Statement, please contact Huan Lou, Esq. (hlou@srfc.law or (646) 810-2187)
or David Manno, Esq. (dmanno@srfc.law or (212) 981-6772) of Sichenzia Ross Ference Carmel LLP, attorneys for MKDWELL Tech Inc., and Michael
T. Campoli, Esq. (mcampoli@pryorcashman.com or (212) 326-0468) or Elizabeth F. Chen, Esq. (echen@pryorcashman.com or (212)
326-0199), attorneys for Cetus Capital Acquisition Corp.

Thank
you for your time and attention.

    Very
    truly yours,

    /s/
    Ming-Chia Huang

    Ming-Chia
    Huang

    On
    behalf of MKDWELL Tech Inc.

    /s/
    Chung-Yi Sun

    Chung-Yi
    Sun

    On
    behalf of Cetus Capital Acquisition Corp.