United States securities and exchange commission logo





                          September 8, 2022

       Tom McHugh
       Chief Financial Officer
       Avadel Pharmaceuticals PLC
       16640 Chesterfield Grove, Suite 200 Road
       Chesterfield, MO 63005

                                                        Re: Avadel
Pharmaceuticals PLC
                                                            Registration
Statement on Form S-3
                                                            Filed August 31,
2022
                                                            File No. 333-267198

       Dear Mr. McHugh:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Doris
Stacey Gama at 202-551-3188 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Finn Murphy, Esq.