United States securities and exchange commission logo

                            February 1, 2021

       Peter (Peizhi) Luo
       Chief Executive Officer
       Adagene Inc.
       4F, Building C14, No. 218
       Xinghu Street, Suzhou Industrial Park
       Suzhou, Jiangsu Province, 25125
       People's Republic of China

                                                        Re: Adagene Inc.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed February 1,
                                                            File No. 333-252210

       Dear Mr. Luo:

              We have reviewed your amended registration statement and have the
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Amendment No. 1 to Registration Statement on Form F-1 filed February 1,

       17. Subsequent Events, page F-39

   1.                                                   For the November 9,
2020 option modifications, please remove the disclosure stating the
                                                        modification is exempt
under ASU 2017-09, as modifications to vesting terms do not
                                                        qualify for exemption
from modification of awards accounting under ASC 718. Please
                                                        disclose the amount of
compensation expense to be recognized during the fourth quarter
                                                        of fiscal year 2020
from waiving the remaining vesting schedule and conditions (i.e., the
                                                        amount of unrecognized
compensation expense remaining to be recognized since the date
                                                        of grant) for the
2,375,000 options.
 Peter (Peizhi) Luo
Adagene Inc.
February 1, 2021
Page 2

       You may contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jason Drory at 202-551-8342 or Celeste Murphy at 202-551-3257 with any

FirstName LastNamePeter (Peizhi) Luo
                                                          Division of
Corporation Finance
Comapany NameAdagene Inc.
                                                          Office of Life
February 1, 2021 Page 2
cc:       Li He, Esq.
FirstName LastName