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February 26, 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. 7 to Registration Statement on Form F-1
Filed February 12, 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. Unless we note otherwise,
any references to prior comments are to comments in our January 10, 2024 letter.
Amendment No. 7 to Registration Statement on Form F-1, Filed February 12, 2024
Distribution Network, page 4
1.We note your disclosure that the total number of direct and indirect customer relationships
established overseas through the PRC subsidiaries' exporting distributors was
approximately 50 and 100 as of September 30, 2023 and 2022, respectively, and that the
decline was attributed to a decreased demand for masks and other medical devices
overseas following the easing of COVID-19 restrictions and the diminishing impact of the
pandemic since the first quarter of 2023, along with the PRC subsidiaries having placed
more emphasis on screening client qualifications, preferring to collaborate with major
clients, which has resulted in reduced number of clients. Please disclose whether you
expect this trend to continue in future financial periods and the related impact to your
business and operations if the number of customer relationships continues to decline.

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 February 26, 2024 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
February 26, 2024
Page 2
Dividends and Other Distributions, page 9
2.We note that you have removed disclosure quantifying certain cash transfers as of certain
financial periods in the filing. Please reinstate this disclosure, and state whether any
transfers, dividends, or distributions have been made to date between the company and its
subsidiaries, and quantify the amounts where applicable.
General
3.We note your revisions to prior comment 1 and reissue in part. Since the filing of the
amendment on November 6, 2023, certain disclosure appearing on the cover page,
Summary, Risk Factor and Regulation sections relating to legal and operational risks
associated with operating in China and PRC regulations has been removed, and we do not
believe that your revised disclosure continues to convey the same risk. Please restore your
disclosures in these areas to the disclosures as they existed in your amendment filed on
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.