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CORRESP
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 MKDWELL
Tech Inc.

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

 Hsinchu
Science Park,

 Hsinchu
City 300, Taiwan

 June
10, 2025

 Securities
and Exchange Commission

 Division
of Corporate Finance

 Office
of Manufacturing

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Stephany Yang and Melissa Gilmore

 Re:

 MKDWELL
 Tech Inc.

 Form
 20-F for Fiscal Year Ended December 31, 2024

 Filed
 April 3, 2025

 File
 No. 001-42197

 Dear
Ms. Stephany Yang and Ms. Melissa Gilmore

 Please
find below our responses to the questions raised by the staff (the "Staff") of the Securities and Exchange Commission (the
"Commission") in its letter of comments dated May 28, 2025 (the "Comment Letter") relating to the annual report
on Form 20-F for Fiscal Year Ended December 31, 2024, which was filed with the Commission by MKDWELL Tech Inc. (the "Company"
or "we") on April 3, 2025 (the "Annual Report"). The Company is concurrently filing an amendment to the Annual
Report herewith (the "Amendment").

 Capitalized
terms used but not defined in this letter have the meanings ascribed to such terms in the Amendment and the Annual Report.

 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.

 Response:
The Company respectfully confirms that future filings of its annual report on Form 20-F will include the required disclosures in the format as follows:

 Cash
Transfers And Distributions in the Group

 Cash
may be transferred between the Company and its subsidiaries in the following manner: (1) funds may be transferred to the Company's
subsidiaries from the Company or intermediate holding companies in the Group as needed in the form of capital contribution or shareholder
loans; (2) dividends or other distributions may be paid by the Company's subsidiaries to the Company or any intermediate holding
company; and (3) the Company's subsidiaries may lend to and borrow from each other from time to time for business operation purposes.
The Company and its subsidiaries are permitted under PRC laws and regulations to provide funding to the Company's PRC subsidiaries
in the form of loans or capital contributions, provided that the applicable governmental registration and approval requirements are satisfied.
Cash proceeds raised from financings conducted outside of China, may be transferred to the Company's PRC subsidiaries via capital
contribution or shareholder loans.

 For
the past three fiscal years ended December 31, 2024 and up to March 31, 2025, no dividends or distributions were made to U.S. investors.

 For
the year ended December 31, 2022, within the MKD group (based on the currency conversion rates of 1 USD to 6.73 CNY; 1 USD to 29.80 NTD):

 ●
 MKD
 Jiaxing made payments for goods of a total sum of $133,749 to MKD Taiwan.

 ●
 MKD
 Taiwan made payments for goods of a total sum of $21,209 to MKD Jiaxing.

 ●
 MKD
 Shanghai provided working capital loans of $193,193 to MKD Jiaxing.

 ●
 MKD
 Jiaxing repaid a working capital loan in the amount of $44,583 to MKD Shanghai.

 For
the year ended December 31, 2023, within the MKD group (based on the currency conversion rates of 1 USD to 7.08 CNY; 1 USD to 31.1525
NTD):

 ●
 MKD
 Jiaxing made payments for goods of a total sum of $464,952 to MKD Taiwan and $840,183 to MKD Shanghai.

 ●
 MKD
 Shanghai made payments for goods of a total sum of $319,273 to MKD Jiaxing.

 ●
 MKD
 Taiwan provided working capital loans of $20,843 to MKD BVI.

 ●
 MKD
 BVI provided working capital loans of $360,000 to MKD Taiwan.

 ●
 MKD
 Taiwan repaid a working capital loan in the amount of $360,000 to MKD BVI.

 ●
 MKD
 Shanghai provided working capital loans of $96,041 to MKD Jiaxing.

 ●
 MKD
 Jiaxing repaid a working capital loan in the amount of $56,495 to MKD Shanghai.

 For
the year ended December 31, 2024, within the MKD group (based on the currency conversion rates of 1 USD to 7.20 CNY; 1 USD to 32.1064
NTD):

 ●
 MKD
 Taiwan made payments for goods of a total sum of $268,050 to MKD Jiaxing.

 ●
 MKD
 Jiaxing provided working capital loans in the amount of $2,602,943 to MKD Shanghai.

 ●
 MKD
 Shanghai provided working capital loans in the amount of $1,988,688 to MKD Jiaxing.

 ●
 MKD
 Taiwan provided working capital loans of $403,000 to MKD BVI.

 ●
 MKD
 Jiaxing provided a working capital loan in the amount of $250,000 to MKD BVI.

 ●
 MKD
 Shanghai repaid working capital loans in the amount of $2,602,943 to MKD Jiaxing.

 ●
 MKD
 Jiaxing repaid working capital loans in the amount of $1,988,688 to MKD Shanghai.

 ●
 MKD
 BVI repaid a working capital loan in the amount of $50,000 to MKD Taiwan.

 ●
 MKD
 Taiwan provided working capital loans of $24,000 to MKDWELL Tech Inc.

 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 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.

 Response:

 During
the reporting period ended December 31, 2024, the Company has evaluated all three legal matters disclosed in its annual report on Form
20-F in accordance with ASC 450-20:

 (a)
Accrual Status of Legal Matters

 (1)
Financial Leasing Contract Dispute

 We have accrued RMB1.3 million ($0.18 million)
under "Accrued expenses and other current liabilities" (constituting a portion of the item "Long-term
payments of leaseback, current" of $1,242,154 as at December 31, 2024), and RMB1.5 million ($0.21 million) under "Other
non-current liabilities" on our balance sheet (constituting a portion of the item "Long-term payments of leaseback"
of $270,412 as at December 31, 2024). The amount represents the present value of future cash outflows as of December 31, 2024, calculated
using the original contract's discount rate of 9.4%. While the plaintiff may demand the return of the remaining rent and payment
of liquidated damages which is less than the amount the Company has already accrued, the Company maintains that its accrual is reasonable
based on facts and legal assessments as of December 31, 2024.

 (2)
Amended Satisfaction and Discharge Agreement

 The
full amount of $662,500 has been accrued under "Accrued expenses and other liabilities" as disclosed on the item "Deferred
underwriter commission payable" in Note 12 of our financial statements. This obligation is fixed and uncontested.

 (3)
Litigation with Former U.S. Legal Advisor

 An
action was commenced against us in December 2024 in the Supreme Court of the State of New York by the previous U.S. legal advisor of
Cetus Capital, which became our subsidiary after the closing of the Business Combination, relating to certain legal fees owed. Such action
sought relief for a sum of $478,715, interest thereon at 10 percent. per annum, costs and expenses, including reasonable attorneys'
fees, and such other and further relief as deemed just and proper. We have accrued $478,715 and 10% interest amount of $19,411 under
"Accrued expenses and other liabilities". Regarding related reasonable attorneys' fees, as we have not received a claim
on the specific amount of attorney's fee, we are unable to quantify this amount and therefore no accrual has been recorded as the
loss contingency does not meet the "probable and estimable" threshold under ASC 450-20. We have disclosed on page F-35 of
our annual report.

 (b)
ASC 450-20-50 Compliance

 (1)
The guidelines are as follows:

 Disclosure
of the nature of an accrual made pursuant to the provisions of paragraph 450-20-25-2, and in some circumstances the amount accrued, may
be necessary for the financial statements not to be misleading. If no accrual is made for a loss contingency because one or both of the
conditions in paragraph 450-20-25-2 are not met, disclosure of the contingency shall be made when there is at least a reasonable possibility
that a loss or an additional loss may have been incurred. The disclosure shall indicate: (A) The nature of the contingency, and (B) An
estimate of the possible loss or range of loss (or state that such an estimate cannot be made).

 (2)
Our consideration:

 Regarding
the above matter, we have fully accrued all liabilities on our accounting records except for related reasonable attorneys' fees.
Pursuant to ASC 450-20-50 requirements, no additional disclosure in Note 21 of our financial statements is required. As for related reasonable
attorneys' fees that were not able to be quantified as at December 31, 2024, we have state that such an estimate cannot be made
in Note 21 of our financial statements.

 (c)
Item 8.A.7 of Form 20-F

 In
addition, with respect to Item 8.A.7 of Form 20-F, the Company has evaluated all legal proceedings that could materially impact our financial
position. The Company respectfully confirms that future filings of its annual report on Form 20-F will include the required disclosures in the format as follows:

 Legal
proceedings

 From
time to time, we may be subject to various legal proceedings and claims that arise in the ordinary course of business, including such
as disclosed in "Item 13. Defaults, Dividend Arrearages and Delinquencies". We have evaluated all legal proceedings that
could materially impact our financial position. We are currently not a party to, and we are not aware of any threat of, any legal or
administrative proceedings that, in the opinion of our management, are likely to have any material adverse effect on our business, financial
condition, cash-flow or results of operations.

 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.

 Response:
The Company respectfully confirms that future filings of its annual report on Form 20-F will include the required disclosures in the format as follows:

 ITEM
15. CONTROLS AND PROCEDURES

 Disclosure
Controls and Procedures Evaluation

 Under
the supervision and with the participation of our management, including our chief executive officer and chief financial officer, we carried
out an evaluation of the effectiveness of our disclosure controls and procedures, which is defined in Rule 13a-15(e) of the Exchange
Act, as of December 31, 2024. Based on that evaluation, our chief executive officer and chief financial officer concluded that our disclosure
controls and procedures as of December 31, 2024, were not effective.

 Management's
Annual Report on Internal Control over Financial Reporting

 Our
management, including our chief executive officer and chief financial officer, is responsible for establishing and maintaining adequate
internal control over financial reporting, as such term is defined in Exchange Act Rule 13a-15(f). Our internal control over financial
reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation
of financial statements for external purposes in accordance with U.S. Generally Accepted Accounting Principles ("U.S. GAAP").
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections
of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in
conditions or because the degree of compliance with policies or procedures may deteriorate. Under the supervision and with the participation
of our management, including our chief executive officer and chief financial officer, we conducted an assessment of the effectiveness
of our internal control over financial reporting as of December 31, 2024. The assessment was based on criteria established in the framework
Internal Control-Integrated Framework (2013), issued by the Committee of Sponsoring Organizations of the Treadway Commission.

 In
relation to the examination of our combined and consolidated financial statements presented in this Annual Report, we have identified
material weaknesses in our internal control over financial reporting and as such our internal control over financial reporting as of
December 31, 2024 were not effective. The Company did not have a formal risk assessment process and internal control framework over financial
reporting, which included the lack of a formal group-wide risk assessment process to identify, assess, address or mitigate the risks
identified, and sufficient internal control over a financial reporting framework to maintain effective internal controls within the organization,
and which may increase risk of error, fraud, misstatement of financial reporting, or non-compliance with related regulations for a U.S.
listed group. Additionally, the Company lacked sufficient financial reporting and accounting personnel with appropriate knowledge of
GAAP and SEC reporting requirements to properly address complex GAAP technical accounting issues and to prepare and review financial
statements and related disclosures in accordance with GAAP and reporting requirements set forth by the SEC.

 A
comprehensive assessment of our internal control, aimed at identifying and reporting material weaknesses and other deficiencies, was
not conducted by our independent registered public accounting firm. Performing such an assessment or having an audit of our internal
control over financial reporting might have revealed additional deficiencies.

 To
address the identified material weaknesses stemming from the audit of our combined and consolidated financial statements for the year
ended December 31, 2024, we intend to implement various measures, including the hiring of additional accounting personnel to enhance
the financial reporting function and the establishment of a financial and system control framework. We also intend to initiate regular
U.S. GAAP and SEC financial reporting training programs for our accounting and financial personnel. Moreover, we are in the process of
developing and implementing a set of policies and procedures for period-end financial reporting. However, we cannot provide assurance
that these measures will be entirely effective in remediating the material weaknesses in a timely manner or at all.

 Attestation
Report of the Registered Public Accounting Firm

 Being
a company with less than US$1.235 billion in revenue for the fiscal year ended December 31, 2023, we qualify as an "emerging growth
company" under the JOBS Act. An emerging growth company is entitled to certain reduced reporting and other requirements that are
typically appl