United States securities and exchange commission logo

                             December 9, 2020

       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. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted November
24, 2020
                                                            CIK No.: 0001818838

       Dear Mr. Luo:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       November 10, 2020 letter.

       Draft Registration Statement on Form F-1 Submitted on November 24, 2020

       Prospectus Summary
       Our Pipeline, page 5

   1.                                                   We note your response
to our prior comment 2 and your revised pipeline table that
                                                        shows your trial 1001
for ADG126 has already commenced Phase Ia. However, your
                                                        disclosures only
indicate that you have received authorization to begin the trial from the
                                                        Australian authorities,
and from the FDA, subject to submission of a revised agreed-upon
 Peter (Peizhi) Luo
FirstName  LastNamePeter (Peizhi) Luo
Adagene Inc.
December   NameAdagene
              2020        Inc.
Page  2    9, 2020 Page 2
FirstName LastName
         protocol, but not that the trial has commenced. Please reconcile your
disclosures. In
         addition, please explain why it is appropriate to show Phase Ia and
Phase Ib as two
         separate columns when your discussions for ADG126 and ADG116 only
refer to "Phase
         I". Please also explain why it is appropriate to retain the US 1001
trial for ADG116 in the
         pipeline table when you do not currently plan to enroll patients in
this clinical trial.
ADG126: Novel anti-CTLA-4 SAFEbody candidate, page 7

2.       We note your use of the phrase "potency" to describe certain
preclinical observations. For
         example only, we note your revised disclosures here and elsewhere in
your prospectus
         where you state that "ADG126 in addition to its potency for Treg
depletion in TME
         suggests its potential for tolerable and potent monotherapies" and
that "preclinical results
         support the further clinical evaluation of ADG116 both as tolerable
and potent
         monotherapies and combination therapies for a wide range of tumor
types." As ADG126
         is only in the preclinical stage, and as safety and efficacy
determinations are solely within
         the FDA's authority and they continue to be evaluated throughout all
phases of clinical
         trials, please remove these and any similar references. Where you deem
appropriate, you
         may present objective data resulting from your trials without
including your conclusions
         related to safety or efficacy.
Notes to the Consolidated Financial Statements
18. Condensed Financial Information of the Parent Company, page F-40

3.       Please disclose the amount of the restricted net assets for each
subsidiary in accordance
         with Article 4-08(e)(3)(ii) of Regulation S-X. To the extent that
restricted net assets of
         your consolidated subsidiaries does not exceed 25 percent of
consolidated net assets as of
         December 31, 2019 in accordance with Article 5-04(c) of Regulation
S-X, please disclose
         the purpose of presenting the parent company financial information.
4.       Please disclose the related party transactions recognized in your
statements of
         comprehensive loss and statements of cash flows in accordance with
Article 4-08(k)(i) of
         Regulation S-K. In addition, disclose any intercompany profits or
losses resulting from
         transactions with related parties and the effects of those
transactions in accordance with
         Article 4-08(k)(ii) of Regulation S-X. As part of your response, tell
us what services you
         provided and who the related party is for the revenue recognized for
fiscal year 2019.
 Peter (Peizhi) Luo
Adagene Inc.
December 9, 2020
Page 3

       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 Dorrie Yale at 202-551-8776 with any
other questions.

FirstName LastNamePeter (Peizhi) Luo
                                                          Division of
Corporation Finance
Comapany NameAdagene Inc.
                                                          Office of Life
December 9, 2020 Page 3
cc:       Li He, Esq.
FirstName LastName