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                              October 12, 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. 4 to
Registration Statement on Form F-1
                                                            Filed September 29,
2023
                                                            File No. 333-271474

       Dear Shuang Wu:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our August 31, 2023
letter.

       Amendment No. 4 to Registration Statement on Form F-1

       Cover Page

   1.                                                   We note your statement
that you are not required to submit an application to the CSRC for
                                                        its approval of this
offering and the listing and trading of your Ordinary Shares with
                                                        Nasdaq under the M&A
Rules, while you will nevertheless have to file with the CSRC in
                                                        accordance with the
Trial Administrative Measures with respect to this offering. Please
                                                        revise to expressly
state whether this offering requires CSRC approval under the Trial
                                                        Administrative
Measures.
       Interim Financial Statements, page F-29

   2.                                                   Your audited financial
statements are currently older than 12 months and this is an initial
                                                        public offering of your
ordinary shares. Accordingly, please update your financial
 Shuang Wu
WORK Medical Technology LTD
October 12, 2023
Page 2
      statements pursuant to Item 8.A.4 of Form 20-F or provide the appropriate
representations
      in an exhibit. Refer to Instruction 2 to Item 8.A.4. In addition, please
have your
      independent accounting firm provide an updated consent as Exhibit 23.1.
Note 12. Related Party Transactions, page F-43

3.    We have reviewed your response to prior comment 5. Please clarify whether
the
      compensation to your CEO and CFO has been recorded in your financial
statements. If no
      amount has been recorded, please revise your financial statements to
include
      compensation or explain why a revision is not necessary.
       Please 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,

FirstName LastNameShuang Wu                               Division of
Corporation Finance
                                                          Office of Industrial
Applications and
Comapany NameWORK Medical Technology LTD
                                                          Services
October 12, 2023 Page 2
cc:       Ying Li, Esq.
FirstName LastName