United States securities and exchange commission logo

                             May 6, 2022

       Peter (Peizhi) Luo
       Chief Executive Officer
       Adagene Inc.
       4F, Building C14, No. 218
       Xinghu Street, Suzhou Industrial Park
       Suzhou, Jiangsu Province, 215123
       People   s Republic of China

                                                        Re: Adagene Inc.
Statement on Form F-3
                                                            Filed April 26,
                                                            File No. 333-264486

       Dear Mr. Luo:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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-3

       Cover Page

   1.                                                   Please revise your
cover page to state whether your auditor is subject to the
announced by the PCAOB on December 16, 2021 and whether and how
                                                        the Holding Foreign
Companies Accountable Act and related regulations, including the
                                                        potential Accelerating
Holding Foreign Companies Accountable Act, will affect your
                                                        company. In your
revisions, please discuss the time periods for any potential prohibition
                                                        on trading.
 Peter (Peizhi) Luo
FirstName  LastNamePeter (Peizhi) Luo
Adagene Inc.
May  6, 2022NameAdagene Inc.
May 6,
Page  2 2022 Page 2
FirstName LastName
2.       Please provide prominent disclosure here, in the Our Company section
and in Risk
         Factors disclosing that you were provisionally identified by the
Commission on May 4,
         2022 under the HFCAA. Refer to https://www.sec.gov/hfcaa.
3.       Please revise your prospectus cover page to clarify that any potential
secondary offerings
         of securities made pursuant to the registration statement are limited
to currently
         outstanding securities. For guidance, please refer to General
Instruction I.B.3 of Form F-3.
Our Company, page 3

4.       Please revise this section, where appropriate, to state whether you or
your subsidiaries are
         covered by permissions requirements from the China Securities
Regulatory Commission
         (CSRC), Cyberspace Administration of China (CAC) or any other
governmental agency
         that is required to approve your or your subsidiaries' operations.
Please also describe the
         consequences to you and your investors if you or your subsidiaries:
(i) do not receive or
         maintain such permissions or approvals, (ii) inadvertently conclude
that such permissions
         or approvals are not required or (iii) applicable laws, regulations,
or interpretations change
         and you are required to obtain such permissions or approvals in the
Transfer of Funds and Other Assets, page 13

5.       Please revise your disclosure to state whether you have specific cash
management policies
         and procedures in place that dictate how funds are transferred through
your organization
         and if applicable, describe these policies and procedures in greater
Risk Factors
Failure to comply with existing or future laws..., page 21

6.       Please revise the disclosure underneath this heading, or elsewhere, as
appropriate, to
         explain to what extent you believe you are compliant with the
regulations or policies that
         have been issued by the CAC to date.
Enforceability of Civil Liabilities, page 70

7.       Please expand your disclosure to specifically discuss whether you have
officers or
         directors located in China, and if so, address the difficulty of
bringing actions and
         enforcing judgments against individuals located in China. Please also
include relevant
         summary risk factor and risk factor disclosure, as applicable.

8.       With reference to General Instruction I.B.3 of Form F-3, please revise
your Exhibit 5.1
         opinion with respect to the securities to be potentially offered by
selling shareholders to
         clarify that such securities were duly authorized and are currently
validly issued, fully
         paid and non-assessable.

         We remind you that the company and its management are responsible for
the accuracy
 Peter (Peizhi) Luo
Adagene Inc.
May 6, 2022
Page 3

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

       Please contact Alan Campbell at 202-551-4224 or Celeste Murphy at
202-551-3257 with
any questions.

FirstName LastNamePeter (Peizhi) Luo
                                                           Division of
Corporation Finance
Comapany NameAdagene Inc.
                                                           Office of Life
May 6, 2022 Page 3
cc:       Xuelin (Steve) Wang, Esq.
FirstName LastName