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                              May 9, 2023

       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
                                                            Registration
Statement on Form F-1
                                                            Filed April 27,
2023
                                                            File No. 333-271474

       Dear Shuang Wu:

              We have reviewed your 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1, Filed April 27, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Liquidity and Capital Resources, page 66

   1.                                                   We note the increase in
accounts receivable of $4,234,997 was due to the "liquidation
                                                        difficulties of our
customers under the impact of pandemic." Since accounts receivable is
                                                        significant when
compared to total current assets, please describe for us in further detail
                                                        the liquidation
difficulties you reference and tell us the amount of accounts receivable that
                                                        have been subsequently
collected in cash.
 Shuang Wu
FirstName  LastNameShuang
WORK Medical    Technology Wu
                           LTD
Comapany
May  9, 2023NameWORK Medical Technology LTD
May 9,
Page 2 2023 Page 2
FirstName LastName

2.       We note accounts receivable, net increased from $302,424 to
$3,287,817, whereas
         revenue decreased 57%. We also note bad debt as a percentage of
revenue increased from
         0.2% to 6.4%. In light of these year-over-year changes, please revise
your revenue
         recognition accounting policy in the notes to the financial statements
to specifically
         address your revenue recognition accounting policy for sales made to
distributors. As part
         of your accounting policy, address why it is appropriate to recognize
revenue upon
         transfer and acceptance of the products to your distributors, and not
upon sell through by
         the distributors to the end customers. In addition, disclose the
specific payment terms
         your offer your distributor customers and whether you offer your
distributors any rights of
         return or refunds. Lastly, describe for us the facts and circumstances
surrounding the bad
         debt recorded during the year ended September 30, 2022.
3.       Please clarify your disclosure on page 86 to quantify the amount of
revenue attributable to
         distributor customers for each year.
4.       We note on page F-22, note (3), that amounts due from related parties
include accounts
         receivable for selling medical consumables. Please separately disclose
on the face of the
         consolidated balance sheets Accounts receivable - Related Party.
Similarly, disclose on
         face of the consolidated statements of income the amount of revenue
attributable to related
         parties, as set forth on page F-23.
Related Party Transactions, page 121

5.       We note your statement on page 121: "All the loans to related parties
are expected to be
         repaid in full before the public filing of this registration
statement, but will be depicted as
         outstanding in the Group   s financial statements through September
30, 2022." Now that
         you have made your public filing of this registration statement please
update this
         disclosure to state whether these related party loans have been repaid
in full.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       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 Margaret Schwartz at 202-551-7153 or Celeste Murphy at 202-551-3257
with any other
questions.
 Shuang Wu
WORK Medical Technology LTD
May 9, 2023
Page 3

                                           Sincerely,

FirstName LastNameShuang Wu                Division of Corporation Finance
                                           Office of Industrial Applications
and
Comapany NameWORK Medical Technology LTD
                                           Services
May 9, 2023 Page 3
cc:       Ying Li, Esq.
FirstName LastName