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Correspondence 0001213900-26-032330 from WORK Medical Technology Group LTD (WOK)

WORK Medical Technology Group LTD
Date: March 20, 2026 · CIK: 0001929783 · Accession: 0001213900-26-032330

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File numbers found in text: 001-42256, 333-289943

Referenced dates: March 12, 2026

Date
March 20, 2026
Author
/s/ Shuang Wu
Form
CORRESP
Company
WORK Medical Technology Group LTD

Letter

March 20, 2026

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: Al Pavot

Terence O'Brien

Re: WORK Medical Technology Group LTD

Form 20-F filed January 30, 2026 (File No. 001-42256)

Ladies and Gentlemen:

This letter is in response to the letter dated March 12, 2026, 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 Annual Report on Form 20-F/A ("Amendment No. 1 to Form 20-F") is being filed to accompany this letter.

Form 20-F filed January 30, 2026

Item 19, page

1. Please revise the accountant's consent in Exhibit 15.2 to include the complete file number of the Form F-3. Also, please include a consent that covers the audit report on your September 30, 2025 financial statements. See the guidance in Item 6 of Form F-3.

In response to the Staff's comments, our former auditor, WWC, P.C. has revised Exhibit 15.2 to include the complete file number on Form F-3 (File No. 333-289943), filed with the Commission on August 29, 2025 and went effect on September 15, 2025. In addition, our current auditor, HTL International, LLC, has provided their consent in a separate Exhibit 15.3 covering the audit report relating to our consolidated financial statements for the year ended September 30, 2025.

We have filed Amendment No. 1 to Form 20-F to reflect these revisions.

We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Zhaocong "Richard" Xu, Esq., of McLaughlin & Stern, LLP, at (212) 448-1100.

Very truly yours,
/s/ Shuang Wu

Show Raw Text
CORRESP
 1
 filename1.htm

 March 20, 2026

 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:
 Al Pavot

 Terence O'Brien

 Re:
 WORK Medical Technology Group LTD

 Form 20-F filed January
 30, 2026 (File No. 001-42256)

 Ladies and Gentlemen:

 This letter is in response
to the letter dated March 12, 2026, 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 Annual Report on Form 20-F/A
("Amendment No. 1 to Form 20-F") is being filed to accompany this letter.

 Form 20-F
filed January 30, 2026

 Item 19, page
155

 1. Please
revise the accountant's consent in Exhibit 15.2 to include the complete file number of the Form F-3. Also, please include a consent that
covers the audit report on your September 30, 2025 financial statements. See the guidance in Item 6 of Form F-3.

 In response to
the Staff's comments, our former auditor, WWC, P.C. has revised Exhibit 15.2 to include the complete file number on Form F-3 (File
No. 333-289943), filed with the Commission on August 29, 2025
and went effect on September 15, 2025. In addition, our current auditor, HTL International, LLC, has provided their consent in a separate
Exhibit 15.3 covering the audit report relating to our consolidated financial statements for the year ended September 30, 2025.

 We have filed
Amendment No. 1 to Form 20-F to reflect these revisions.

 We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Zhaocong "Richard" Xu, Esq., of
McLaughlin & Stern, LLP, at (212) 448-1100.

 Very truly yours,

 /s/ Shuang Wu

 Name:
 Shuang Wu

 Title:
 Chief Executive Officer, Director, and Chairman of the Board
of Directors

 Cc: McLaughlin & Stern, LLP