United States securities and exchange commission logo January 25, 2021 Thomas McHugh Senior Vice President and Chief Financial Officer AVADEL PHARMACEUTICALS PLC 10 Earlsfort Terrace Dublin 2, Ireland D02 T380 Re: AVADEL PHARMACEUTICALS PLC Form 10-K for the Year Ended December 31, 2019 Filed March 16, 2020 Form 10-Q for the Period Ended June 30, 2020 Filed August 10, 2020 File No. 001-37977 Dear Mr. McHugh: We have completed our review of your filings. 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