Adagene Inc.
4F, Building C14, No. 218
Xinghu Street, Suzhou Industrial Park
Suzhou, Jiangsu Province, 215123
People’s Republic of China
May 28, 2025
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Chris Edwards
Mr. Tyler Howes
Ms. Laura Crotty
Re: Adagene Inc.
Registration Statement on Form F-3
Filed May 9, 2025
File No. 333-287161
Ladies and Gentlemen:
On behalf of Adagene Inc., (the “Company”), and pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the above-referenced Registration Statement on Form F-3 be accelerated so that it will be declared effective at 4:30 p.m. on May 30, 2025, or as soon thereafter as is practicable.
Please direct any questions regarding the foregoing to Xuelin (Steve) Wang at +852 2533-1092 (xuelin.wang@davispolk.com) of Davis Polk & Wardwell LLP, counsel to the Company.
| Sincerely, | |
| /s/ Peter Luo | |
| Peter Luo | |
| Chief Executive Officer | |
| Adagene Inc. |
cc: Xuelin (Steve) Wang, Esq.