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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

2.     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
 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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