December 19, 2018 Michael F. Kanan Senior Vice President and Chief Financial Officer Avadel Pharmaceuticals plc Block 10-1 Blanchardstown Corporate Park Ballycoolin Dublin 15 Ireland Re: Avadel Pharmaceuticals plc Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 16, 2018 and Amended April 30, 2018 File No. 001-37977 Dear Mr. Kanan: 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 Healthcare & Insurance