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August 31, 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. 3 to Registration Statement on Form F-1
Filed August 17, 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 July 12, 2023 letter.
Amendment No. 3 to Registration Statement on Form F-1, Filed August 17, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Net Revenue, page 66
1.We note sales of masks increased 125.1% for the six months ended March 31, 2023, when
compared to the comparable prior period,  Please quantify the impact of (i) the unit price
increase in masks, and of (ii) any foreign currency rate fluctuations, on your increase in
sales.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 August 31, 2023 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
August 31, 2023
Page 2
Business
Research and Development (R&D), page 92
2.We note your disclosure on page 93 regarding your Patent Transfer Agreements
with Zhejiang University and the Second Hospital of Jiaxing City.  Please expand this
disclosure to provide the following information for each agreement, to the extent
applicable:

•the nature and scope of intellectual property transferred;
•each parties’ rights and obligations;
•the duration of the agreement and royalty term;
•the termination provisions;
•the aggregate amounts paid to date under the agreement;
•the aggregate future potential milestone payments to be paid; and
•the royalty rates or a royalty range.

Interim Financial Statements
5. Prepaid Expenses and Other Current Assets, page F-39
3.We note the interest-free loan to third party was $2,038,826, $2,032,473 and $1,706,242
for the periods presented and recorded as a current asset for these periods.  We also note
the amount at March 31, 2023 is significant as it is equal to 41% of your working capital
surplus as of the same date. Please address the following:

•Explain to us why the amount was not fully collected as of March 31, 2023 when it
was recorded as current as of September 30, 2021;
•Explain to us how you determined the amount is fully collectible as of March 31,
2023;
•Disclose when you expect the amount to be paid in full;
•Disclose why the loan was made and identify the party that received the proceeds;
and
•Correct the date on page 69 from March 31, 2022 to March 31, 2023.
Note 12. Related Party Transactions, page F-43
4.We note the amount due from Shuang Wu increased from zero to $996,239 and
it represented the advance to this related party for the Group’s daily operations or the
initial public offering costs, including legal fees and accounting fees.  Please explain to us
in further detail this description, the payment terms of this receivable, and how you
determined the amount is collectible.  In this regard, if amounts are advanced to this
related party for your daily operations or other costs, that appears to imply that these costs
are not being recorded on your financial statements.  Please revise your disclosure, as
appropriate.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 August 31, 2023 Page 3
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
August 31, 2023
Page 3
5.We note on page 125 that you have not paid any compensation to your directors and
officers and on page 126 that neither Shuang Wu, your CEO since June 2022,
nor Ningfang Liang, your CFO since June 2022, own shares in the company.  Please
explain to us why these officers are working without compensation and whether you
expect to pay compensation to them in the future.  In addition, explain to us whether the
$996,239 given to Suang Wu should be recorded as compensation.
6.Please revise your financial statements to reflect the value of the services provided
by Baiming Yu, your Chief Operating Officer since June 2022 and beneficial owner of
50% of your outstanding Ordinary Shares, recorded as an operating expense and
additional paid-in capital.  Refer to SAB Topic 5.T.
            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.