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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.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 June 7, 2023 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
June 7, 2023
Page 2
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.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 June 7, 2023 Page 3
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
June 7, 2023
Page 3
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.