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May 15, 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. 10 to Registration Statement on Form F-1
Filed May 6, 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.
Amendment No. 10 to Registration Statement on Form F-1
Capitalization, page 58
1.Note (1) sets forth that the "As Adjusted" cash has been reduced for all expenses of the
offering, but the actual cash of $1,637,283 and the net proceeds of $5,603,544 does not
add to $8,667,283. The difference appears to be the expenses of the offering identified on
page 161. Please correct the As Adjusted cash amount if necessary or clarify the reason
for the difference.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 68
2.We note your updated disclosure that as of May 1, 2024, approximately $2,630,000 of
accounts receivable outstanding as of September 30, 2023 has been subsequently collected
in cash, with approximately $700,000 remaining outstanding, net. In prior disclosure, we

 FirstName LastNameShuang Wu
 Comapany NameWORK Medical Technology LTD
 May 15, 2024 Page 2
 FirstName LastName
Shuang Wu
WORK Medical Technology LTD
May 15, 2024
Page 2
note that as of February 5, 2024 approximately $2,580,0000 of accounts receivable
outstanding as of September 30, 2023 has been subsequently collected in cash.
Accordingly, approximately $50,000 of collections occurred over the recent three month
period. Please revise your disclosure to address whether collections have slowed and
whether you expect to collect the remaining September 30, 2023 amounts still
outstanding. Please also disclose the amount of any accounts receivable outstanding as of
September 30, 2023 that have been subsequently determined to be uncollectible and that
will be recorded as bad debt expense.
Underwriting
Lock-Up Agreements, page 158
3.We note your disclosure that your officers, directors, and certain shareholders have
agreed, subject to certain exceptions, to enter into lock-up agreements for a period of three
or six months after the offering is completed. Please revise your disclosure throughout the
registration statement to clarify which parties entered into a three month or a six month
lock-up period and the "certain exceptions" to which you refer.
            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 Juan Grana at 202-551-6034 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.