SEC Comment Letter 0000000000-24-007934 to WORK Medical Technology Group LTD (WOK)
WORK Medical Technology Group LTD
Date: July 12, 2024 · CIK: 0001929783 · Accession: 0000000000-24-007934
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File numbers found in text: 333-271474
Letter
July 12, 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. 12 to Registration Statement on Form F-1 Filed July 5, 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. Amendment No. 12 to Registration Statement on Form F-1 Management's Discussion and Analysis of Financial Condition and Results of Operations Business Overview, page 66 1.We note your revised disclosure that the decrease in sales for the period ended March 31, 2024 was primarily due to the decrease in demand and unit price of masks. Please disclose whether you expect this trend to continue in future financial periods, and revise your filing to add a risk factor discussing the risks to your business related to a decrease in demand and unit price of masks. Financing Activities, page 72 We note your revised disclosure that, for the six months ended March 31, 2024, net cash provided by financing activities was $6,556,704, which mainly consisted of proceeds from short-term bank borrowings of $6,244,449. Please revise your disclosure to briefly 2.
July 12, 2024 Page 2 describe the material terms of your short-term bank borrowings. Unaudited Interim Financial Statements Unaudited Condensed Consolidated Balance Sheets, page F-31 3.Please explain to us the reason for the increase in advance to suppliers from $3,469,819 to $7,335,849. In addition, please clarify for us any amount of advance to suppliers that relates to masks or the supplies to produce masks. 4. Inventories, Net, page F-40 4.We note the decline in revenue attributable to masks on page F-38, from $4,752,892 to $566,549. Please tell us the amount of each component of inventories as of March 31, 2024 that is attributable to masks and the amount of mask related inventory you do not expect to consume within 12 months of the balance sheet date, if any. If there is any significant amount that you do not expect to consume within 12 months of the balance sheet date, please clarify for us how you determined a write down to net realizable value was not required. In this regard, we note impairment was nil for the six months ended March 31, 2024. 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.
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July 12, 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. 12 to Registration Statement on Form F-1
Filed July 5, 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.
Amendment No. 12 to Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Business Overview, page 66
1.We note your revised disclosure that the decrease in sales for the period ended March 31,
2024 was primarily due to the decrease in demand and unit price of masks. Please disclose
whether you expect this trend to continue in future financial periods, and revise your
filing to add a risk factor discussing the risks to your business related to a decrease in
demand and unit price of masks.
Financing Activities, page 72
We note your revised disclosure that, for the six months ended March 31, 2024, net cash
provided by financing activities was $6,556,704, which mainly consisted of proceeds
from short-term bank borrowings of $6,244,449. Please revise your disclosure to briefly 2.
July 12, 2024
Page 2
describe the material terms of your short-term bank borrowings.
Unaudited Interim Financial Statements
Unaudited Condensed Consolidated Balance Sheets, page F-31
3.Please explain to us the reason for the increase in advance to suppliers from $3,469,819 to
$7,335,849. In addition, please clarify for us any amount of advance to suppliers that
relates to masks or the supplies to produce masks.
4. Inventories, Net, page F-40
4.We note the decline in revenue attributable to masks on page F-38, from $4,752,892 to
$566,549. Please tell us the amount of each component of inventories as of March 31,
2024 that is attributable to masks and the amount of mask related inventory you do not
expect to consume within 12 months of the balance sheet date, if any. If there is any
significant amount that you do not expect to consume within 12 months of the balance
sheet date, please clarify for us how you determined a write down to net realizable value
was not required. In this regard, we note impairment was nil for the six months ended
March 31, 2024.
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.