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                           October 24, 2022

       Shuang Wu
       Chief Executive Officer
       WORK Medical Technology LTD
       Floor 23, No. 2 Tonghuinan Road
       Xiaoshan District, Hangzhou City, Zhejiang Province
       The People   s Republic of China

                                                        Re: WORK Medical
Technology LTD
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted October
5, 2022
                                                            CIK No. 0001929783

       Dear Shuang Wu:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 7, 2022 letter.

       Amendment No. 2 to Draft Registration Statement on Form F-1

       Dividends and Other Distributions, page 8

   1.                                                   We acknowledge your
revised disclosures in response to prior comments 5 and 11. Please
                                                        revise to clarify if
Hangzhou Shanyou also declared dividends to Work Hangzhou, its
                                                        95% shareholder.
Additionally, explain what you mean that Hangzhou Shanyou declared
                                                        dividends to your COO
and his spouse to offset amounts that Liwei Zhang and her
                                                        affiliate owed to you.
Please also add a risk factor to discuss risks arising from your
                                                        reliance on a large
number of related party transactions to conduct ordinary business
                                                        transactions, or
advise.
 Shuang Wu
WORK Medical Technology LTD
October 24, 2022
Page 2
Intellectual Property, page 93

2.     We note that certain of your patents will expire from 2023 through 2025
and refer to our
       prior comment 16 in our letter dated July 20, 2022. Please revise to
disclose what effect, if
       any, you expect the expiration of these patents to have on your patent
portfolio and your
       business and if you intend to take any action to mitigate such effect.
Unaudited Condensed Consolidated Financial Statements for the Six Months Ended
March 31,
2022 and 2021
4. Inventories, net, page F-36

3.     We note on page 64 that sales of masks decreased 93.0% due mainly to a
decrease in
       demand and unit price. Please clarify for us how your determined that
the net realizable
       value of the related finished goods inventory and work in process is not
lower than its
       cost, as set forth in ASC 330-10-35-18. Provide any underlying analysis
to support your
       conclusion that an impairment of inventory was not necessary for the six
month period
       ended March 31, 2022.
       You may contact Michael Fay at 202-551-3812 or Daniel Gordon at
202-551-3486 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ada Sarmento at 202-551-3798 or Dorrie Yale at 202-551-8776 with any
other
questions.



                                                             Sincerely,

FirstName LastNameShuang Wu                                  Division of
Corporation Finance
                                                             Office of
Industrial Applications and
Comapany NameWORK Medical Technology LTD
                                                             Services
October 24, 2022 Page 2
cc:       Ying Li, Esq.
FirstName LastName