Wu Tinghan was born only 19 years later after Wang Yangming. Same as Luo Qinshun and Wang Tingxiang, Wu Tinghan jumped out of Zhuzi School's frame, and was rebelling against the newly prosperous Yangming School of Mind, then he creatively established the paradigm of Naturalistic Qi-based Philosophy. His philosophy has been unknown to most of the Chinese scholars, yet in Japan, his philosophy had quite an influence, and had participated in the formation of the “Ancient Learning School”. This paper uses Ji-Zhai-Man-Lu as the main subject for discussion. In this paper, the author explains orderly what was the pathe that Wu's philosophical thinking took. Other than that, this paper reports about Wu's basic claims of Qi-based theory (Qi itself is “Principle”, Qi itself if “Tao”), and his Mind-Nature theory following his Qi-based theory (What is inborn is called nature; Nature is the same as Qi, Nature outweighs mind), as well as his self-cultivation theory (be watchful and cautious when alone so as to seek knowledge and then beautify the virtuous nature and finally achieve “full growth of one's nature”). Wu Tinghan's philosophy was a unique type in the early development of Ming and Ching dynasty's Naturalistic Qi-Based Philosophy. The language and words used in his discussion were obscure and ambiguous; and his thinking path was complicated and hard to trace. As a result, the academia has always had difficulties to understand his theories so as to give him a proper position in philosophy history that he deserves. This paper takes Luo Qinshun, Wang Tingxiang and Dai Zhen's Naturalistic Qi-Based philosophies as references for the study, and lays down a relatively clearer thinking path of Wu Tinghan's theory which was hidden under obscure language and writing. By doing so, this paper have ocnfirmed that Wu Tinghan was also a Naturalistic Qi-Based philosopher, and that will be helpful in future studies regarding how to compare and examine Luo, Wang and Wu's philosophies, and the understanding of Ming and Qing Dynasty's Naturalistic Qi-Based Philosophy as a whole, as well as for related Eastern Asian Confucianism History study.