United States securities and exchange commission logo

                      July 11, 2023

       Raymond Tam
       Chief Financial 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.
                                                            Annual Report on
Form 20-F for the fiscal year ended December 31, 2022
                                                            Filed April 28,
                                                            File No. 001-39997

       Dear Raymond Tam:

              We have completed our review of your filing. 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.


                      Division of Corporation Finance

                      Office of Life Sciences
       cc:                                              Xuelin Wang, Esq.