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January 10, 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. 6 to Registration Statement on Form F-1
Filed January 2, 2024
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 November 20, 2023 letter.
Amendment No. 6 to Registration Statement on Form F-1, Filed January 2, 2024
General
1.We note your response to prior comment 1 and the revisions to your disclosure appearing
on the cover page, Prospectus Summary, Risk Factors and Management's Discussion and
Analysis of Financial Condition and Results of Operations sections, relating to legal and
operational risks associated with operating in China and PRC regulations. It is unclear to
us that there have been changes in the regulatory environment in the PRC since the
amendment that was filed on November 6, 2023 warranting revised disclosure to mitigate
the challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may
intervene in or influence your operations at any time, or may exert control over operations
of your business, which could result in a material change in your operations and/or the

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 January 10, 2024 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
January 10, 2024
Page 2
value of the securities you are registering for sale. We remind you that, pursuant to federal
securities rules, the term “control” (including the terms “controlling,” “controlled by,” and
“under common control with”) as defined in Securities Act Rule 405 means “the
possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and regulations in China
can change quickly with little advance notice. We do not believe that your revised
disclosure conveys the same risk. Please restore your disclosures in these areas to the
disclosures as they existed in the registration statement as of November 6, 2023.
            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 Sawicki 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.