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WORK Medical Technology Group LTD

August 17, 2023

Via EDGAR

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Michael Fay

    Daniel Gordon

    Margaret Schwartz

    Katherine Bagley

    Re:
    WORK Medical Technology Group LTD

    Amendment No. 2 to Registration Statement on Form F-1

    Filed on June 30, 2023

    File No. 333-271474

Ladies and Gentlemen:

This letter is in response to the letter dated
July 12, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to WORK Medical Technology Group LTD (the “Company,” “we” and “our”). For the purpose of
the Registration Statement on Form F-1 and this letter, references to “the Group” are to the Company, its British Virgin Islands
subsidiary and its PRC subsidiaries, including Work (Hangzhou) Medical Treatment Technology Co., Ltd., Shanghai Saitumofei Medical Treatment
Technology Co., Ltd., Hunan Saitumofei Medical Treatment Technology Co., Ltd., Hangzhou Woli Medical Treatment Technology Co., Ltd., Hangzhou
Shanyou Medical Equipment Co., Ltd., Shanghai Chuqiang Medical Equipment Co., Ltd., Hangzhou Hanshi Medical Equipment Co., Ltd., and Hangzhou
Youshunhe Technology Co., Ltd., collectively. For ease of reference, we have recited the Commission’s comments in this response
and numbered them accordingly. An amended Registration Statement on Form F-1 (the “Amendment No. 3 to Registration Statement on
Form F-1”) is being submitted to accompany this letter.

Amendment No. 2 to Registration Statement on
Form F-1 filed on June 30, 2023

Liquidity and Capital Resources, page 66

1. We have reviewed your response and revised
disclosure in response to prior comment 3 and have the following comment. Please revise your disclosure to state with greater clarity
that, as of May 31, 2023, you have only collected $589,238 in cash of the $3,287,817 accounts receivable, net, outstanding as of September
30, 2022. In addition, please revise your disclosure to state that $1,336,909 was recorded as bad debt expense in the year ended September
30, 2023 and that this amount relates to revenues from the year ended September 30, 2022. Lastly, please revise your disclosure to state
why you believe the remaining $1,361,770 in accounts receivable is collectible.

In response to the Staff’s comment, we respectfully
advise the Staff that as of July 30, 2023, we collected approximately $2 million in cash of the $3,287,817 accounts receivable, net, outstanding
as of September 30, 2022. In addition, we revised the disclosures on page 66 to state that $1,336,809 was recorded as bad debt and previously
recognized as revenue for the year ended September 30, 2022. Lastly, as 83% of the remaining $1,361,770 in net accounts receivable has
been collected from May 31, 2023 to July 30, 2023, we believe the bad debt provision made for September 30, 2022 was sufficient.

2. In response to prior comment 4 you set forth
that “pursuant to the requirements under ASC 606-10-25-1(e), the Company concluded that the collectability of the full consideration
is probable for revenue recognized during the years ended September 30, 2022 and 2021.” However, we would like to understand the
basis for your determination as it relates to customers with working capital deficiencies. As previously requested, please explain to
us how you assessed collectability, and concluded that the criterion in ASC 606-10-25-1(e) was met, in order to initially record revenue
for customers where you could not collect timely payments. As part of your response, please include actual, factual details, etc.

In response to the Staff’s comments, we
respectfully advise the Staff that in the evaluation, the Group followed the guidance per ASC 606-10-55-3B, which states that the collectability
assessment in paragraph 606-10-25-1(e) is partly a forward-looking assessment. It requires the Group to use judgment and consider all
of the facts and circumstances, including the customary business practices and its knowledge of the customer, in determining whether it
is probable that the Group will collect substantially all of the consideration to which it will be entitled in exchange for the goods
or services that the entity expects to transfer to the customer. The Group constantly evaluated the financial conditions of major customers
when conducting business, such as their most recent collection history, sufficiency of registered capital, and any litigation or negative
news related to these customers in the market. The Group only provides credit sales for trustworthy customers to its best knowledge when
signing the sales contract. Although bad debt provision has been made due to deterioration and instability of some of customers’
financial situations, when the Group is signing the sales contract and thereafter initially recorded revenue, the Group believes it is
probable that it will collect substantially all of the consideration after considered all of the facts and circumstances.

In responding to your comments, the Company acknowledges
that:

 ● the Company is responsible for the adequacy and accuracy of
the disclosure in the filing;

 ● Staff comments or changes to disclosure in response to Staff
comments do not foreclose the Commission from taking any action with respect to the filing; and

 ● the Company may not assert Staff comments as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Shuang Wu

    Name:
    Shuang Wu

    Title:
    Chief Executive Officer, Director, and

Chairman of the Board of Directors

cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC