United States securities and exchange commission logo





                     June 7, 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
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed May 30, 2023
                                                            File No. 333-271474

       Dear Shuang Wu:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our May
9, 2023 letter.
 Shuang Wu
FirstName  LastNameShuang
WORK Medical    Technology Wu
                           LTD
Comapany
June 7, 2023NameWORK Medical Technology LTD
June 7,
Page 2 2023 Page 2
FirstName LastName
Amendment No. 1 to Registration Statement on Form F-1 filed May 30, 2023

Risk Factors
"The PRC subsidiaries are subject to a variety of construction laws . . .",
page 43

1.       We note your amended disclosure that "as to the production lines of
Hangzhou Shanyou,
         it did not obtain a construction license prior to the commencement of
construction nor
         undergone the completion inspection and acceptance nor prepared the
Inspection and
         Acceptance Reports of Construction for the records of the competent
authorities,
         therefore, Hangzhou Shanyou could be fined." Please quantify these
potential fines, if
         estimatable and material. Make conforming changes as appropriate
throughout your risk
         factor disclosure, where you disclose that your subsidiaries are not
in compliance with
         current laws and regulations.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
General and administrative expenses, page 65

2.       You disclose that your PRC subsidiaries could not collect timely
payments from some of
         their customers due to the lack of working capital for the year ended
September 30, 2022.
         Please amend your filing to disclose whether you expect this trend to
continue in future
         periods, and amend your risk factor disclosure to describe the risks
related to your PRC
         subsidiaries being unable to collect timely payments in future
financial periods, if
         applicable.
Liquidity and Capital Resources, page 66

3.       We have reviewed your response to prior comment 1 and note $1,914,900
of accounts
         receivable have been subsequently collected in cash. For the remaining
amounts
         outstanding at September 30, 2022 and not subsequently collected in
cash as of May 31,
         2023, disclose this amount and whether any of it has been recorded as
bad debt. For any
         amounts not subsequently collected in cash or recorded as bad debt as
of May 31, 2023,
         disclose this amount and the reason you have not recorded bad debt
expense.
4.       We have reviewed your revised disclosure in response to prior comment
2 and note the
         credit period varies among different customers and does not exceed one
year. Please
         revise your revenue recognition accounting policy to disclose with
more specificity the
         different payment terms you offer your customers. In addition, you set
forth in your
         response that your PRC subsidiaries could not collect timely payments
from some of their
         customers due to the customers    lack of working capital. Please
explain to us how you
         assessed collectibility, and concluded that the criterion in ASC
606-10-25-1(e) was met, in
         order to initially record revenue for these outstanding amounts.
 Shuang Wu
FirstName  LastNameShuang
WORK Medical    Technology Wu
                           LTD
Comapany
June 7, 2023NameWORK Medical Technology LTD
June 7,
Page 3 2023 Page 3
FirstName LastName
Consolidated Financial Statements
16. Commitments and Contingencies, page F-26

5.       We note the risk factor on page 43 which sets forth that certain
authorities and
         departments "shall" fine you under the circumstances outlined in your
disclosure. Please
         tell us whether any amount of this fine is probable and estimable, and
explain to us the
         basis for your determination. In addition, tell us the consideration
you have given to
         disclosing these potential fines either under this contingencies
footnote or the subsequent
         events footnote.
       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 Katherine Bagley at 202-551-2545
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Industrial Applications and
                                                               Services
cc:      Ying Li, Esq.