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WORK Medical Technology Group LTD

May
17, 2024

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 Sawicki

    Katherine Bagley

    Re:
    WORK Medical Technology Group LTD

    Amendment No. 10 to Registration Statement on Form F-1

    Filed May 6, 2024

    File No. 333-271474

Ladies and Gentlemen:

This letter is in response to the letter dated
May 15, 2024, 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 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
(“Amendment No. 11 to the Registration Statement”) is being submitted to accompany this letter.

Amendment No. 10 to Registration Statement
on Form F-1, Filed May 6, 2024

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.

In response to the Staff’s comments, we
revised the disclosure on page 58 of Amendment No. 11 to the Registration Statement.

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 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.

In response to the Staff’s comments, we
revised the disclosure on page 68 of Amendment No. 11 to the Registration Statement.

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.

In response to the Staff’s comments, we
revised the disclosure on pages 17, 147, and 158 of Amendment No. 11 to the Registration Statement.

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