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United States securities and exchange commission logo
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.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 May 9, 2023 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
May 9, 2023
Page 2
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.

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