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, 2023 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Xuelin Wang, Esq.