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                             May 15, 2024

       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. 10 to
Registration Statement on Form F-1
                                                            Filed May 6, 2024
                                                            File No. 333-271474

       Dear Shuang Wu:

            We have reviewed your amended registration statement and have the
following
       comments.

              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.

       Amendment No. 10 to Registration Statement on Form F-1

       Capitalization, page 58

   1.                                                   Note (1) sets forth
that the "As Adjusted" cash has been reduced for all expenses of the
                                                        offering, but the
actual cash of $1,637,283 and the net proceeds of $5,603,544 does not
                                                        add to $8,667,283. The
difference appears to be the expenses of the offering identified on
                                                        page 161. Please
correct the As Adjusted cash amount if necessary or clarify the reason
                                                        for the difference.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Liquidity and Capital Resources, page 68

   2.                                                   We note your updated
disclosure that as of May 1, 2024, approximately $2,630,000 of
                                                        accounts receivable
outstanding as of September 30, 2023 has been subsequently collected
                                                        in cash, with
approximately $700,000 remaining outstanding, net. In prior disclosure, we
 Shuang Wu
WORK Medical Technology LTD
May 15, 2024
Page 2
      note that as of February 5, 2024 approximately $2,580,0000 of accounts
receivable
      outstanding as of September 30, 2023 has been subsequently collected in
cash.
      Accordingly, approximately $50,000 of collections occurred over the
recent three month
      period. Please revise your disclosure to address whether collections have
slowed and
      whether you expect to collect the remaining September 30, 2023 amounts
still
      outstanding. Please also disclose the amount of any accounts receivable
outstanding as of
      September 30, 2023 that have been subsequently determined to be
uncollectible and that
      will be recorded as bad debt expense.
Underwriting
Lock-Up Agreements, page 158

3.    We note your disclosure that your officers, directors, and certain
shareholders have
      agreed, subject to certain exceptions, to enter into lock-up agreements
for a period of three
      or six months after the offering is completed. Please revise your
disclosure throughout the
      registration statement to clarify which parties entered into a three
month or a six month
      lock-up period and the "certain exceptions" to which you refer.
       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 Juan Grana at 202-551-6034 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
May 15, 2024 Page 2
cc:       Ying Li, Esq.
FirstName LastName