United States securities and exchange commission logo

                               January 28, 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.
Statement on Form F-1
                                                            Filed January 19,
                                                            File No. 333-252210

       Dear Mr. Luo:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, 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 comments apply 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 these comments, we may have additional comments.

       Registration Statement on Form F-1 filed January 19, 2021

       Prospectus Summary, page 1

   1.                                                   We note your revised
disclosure elsewhere in the registration statement regarding the
                                                        Holding Foreign
Companies Accountable Act enacted on December 18, 2020. In
                                                        addition to urging
investors, "to read the entire prospectus carefully, especially the risks of
                                                        investing in the ADSs
discussed under "Risk Factors," "Business," and information
                                                        contained in
"Management's Discussion and Analysis of Financial Condition and Results
                                                        of Operations" before
deciding whether to buy the ADSs," please include additional
                                                        disclosure here,
calling attention to the risk that you could be potentially delisted pursuant
                                                        to the Holding Foreign
Companies Accountable Act.
 Peter (Peizhi) Luo
FirstName  LastNamePeter (Peizhi) Luo
Adagene Inc.
January 28,NameAdagene
            2021         Inc.
Page  2 28, 2021 Page 2
FirstName LastName

Management   s Discussion and Analysis of Financial Condition and Results of
Critical Accounting Policies, Judgments and Estimates
Share-based Compensation, page 131

2.       We note your response to comment 15 in our letter dated October 19,
2020. As verbally
         requested on January 26, 2021 and January 28, 2021, please provide us
with the the
         number of options granted for each grant date. To the extent that a
material portion of
         those grants have subsequently been cancelled or forfeited, please
also tell us the number
         by grant date that has been cancelled and/or forfeited. Finally,
quantify any discounts
         applied to arrive at the deemed fair value of ordinary shares at each
grant date, such as the
         discount for lack of marketability. Once we receive this information,
we may have further
Our Pipeline , page 139

3.       We note your updated graphics on page 141, 142 and 143, depicting your
         development plan. Text in the graphics appear illegible. Please update
these graphics
         accordingly. In addition, we note the graphics contain technical
jargon, including "RP2D"
         and "Traditional 3+3," and elsewhere in your registration statement we
note technical
         terms, such as "SUV scores." Define these terms in a way that a lay
person can
         understand. In addition, please provide narrative disclosure to
clarify your clinical
         development plant for each of your product candidates depicted in your
updated graphics.
Deep, Broad, Differentiated Preclinical Discovery Pipeline, page 172

4.       We note your updated disclosure, including your updated pipeline chart
on page
         173. Please revise your chart to indicate the material stages you will
need to complete
         before marketing your products. For instance, please add Phase I, II
and III to your chart.
         In addition, your pipeline table includes three separate pre-clinical
phases, which gives the
         impression that your product candidates are farther along in the
clinical process. Please
         revise the table to eliminate the separate column for lead
identification, as this stage is not
         sufficiently distinct. Also revise to delete the rows for any
preclinical product candidate
         that is not currently material.
AI-Powered Antibody Discovery, page 176

5.       We note your updated disclosure and your claim that your "DPL platform
is designed to
         substantially improve the probability of success for the overall R&D
process." Given the
         early stage of product candidates and your statement elsewhere that
"the results of [y]our
         current and previous preclinical studies or clinical trials may not be
predictive of future
         results," please remove this claim or otherwise advise.
Compensation of Directors and Executive Officers, page 226
 Peter (Peizhi) Luo
FirstName  LastNamePeter (Peizhi) Luo
Adagene Inc.
January 28,NameAdagene
            2021         Inc.
Page  3 28, 2021 Page 3
FirstName LastName

6.       Please update your executive compensation disclosure to include your
recently completed
         fiscal year. Please refer to Item 6.B of Form 20-F.
Consolidated Statements of Comprehensive Loss, page F-4

7.       Please revise the presentation of expenses to remove the indentation
for the administrative
         expenses line or otherwise clarify that this line is not included in
research and
         development expenses. Please also address this comment for the parent
only financial
         statements included in Note 18 and the interim financial statements.
17. Subsequent Events, page F-40

8.       Please expand your disclosures for the October 2020 and the January
2021 share option
         grants to include the exercise prices, the fair value of the options
granted, and the period
         over which the compensation expense will be recognized. For the
November 2020 share
         options modification, please disclose the amount of additional
compensation expense
         recognized, the exercise price of the share options, and the amount
the promissory notes
18. Condensed Financial Information of the Parent Company, page F-41

9.       We note your response to comment 4. While we note that your
consolidated statements of
         cash flows includes separate line items for cash transactions with
related parties, the
         parent only statements of cash flows does not include these line
items. As previously
         requested, please disclose the related party transactions, including
those transactions with
         the parent's subsidiaries, recognized in your statements of cash flows
in accordance with
         Article 4-08(k)(i) of Regulation S-K.

10.      Refer to prior comment 2. You continue to describe your product
candidates as
         "potent" on pages 6, 140, 148, 156, 157 and elsewhere. Revise these
and all similar
         statements in the document.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

       You may contact Tracey Houser at 202-551-3736 or Terence O'Brien at
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 other
 Peter (Peizhi) Luo
Adagene Inc.
January 28, 2021
Page 4


FirstName LastNamePeter (Peizhi) Luo
                                       Division of Corporation Finance
Comapany NameAdagene Inc.
                                       Office of Life Sciences
January 28, 2021 Page 4
cc:       Li He, Esq.
FirstName LastName