November 20, 2019

Neil F. McFarlane
Chief Executive Officer
Adamas Pharmaceuticals, Inc.
1900 Powell Street, Suite 1000
Emeryville, CA 94608

       Re: Adamas Pharmaceuticals, Inc.
           Registration Statement on Form S-3
           Filed November 7, 2019
           File No. 333-234570

Dear Mr. McFarlane:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-3

General

1.     We note that the forum selection provision in Article VII of your
Amended and Restated
       Certificate of Incorporation identifies the Court of Chancery of the
State of Delaware as
       the exclusive forum for certain litigation, including any "derivative
action." Please
       disclose whether this provision applies to actions arising under the
Securities Act or
       Exchange Act. In that regard, we note that Section 27 of the Exchange
Act creates
       exclusive federal jurisdiction over all suits brought to enforce any
duty or liability created
       by the Exchange Act or the rules and regulations thereunder, and Section
22 of the
       Securities Act creates concurrent jurisdiction for federal and state
courts over all suits
       brought to enforce any duty or liability created by the Securities Act
or the rules and
       regulations thereunder. If the provision applies to Securities Act
claims, please also revise
 Neil F. McFarlane
Adamas Pharmaceuticals, Inc.
November 20, 2019
Page 2
      your prospectus to state that there is uncertainty as to whether a court
would enforce such
      provision and that investors cannot waive compliance with the federal
securities laws and
      the rules and regulations thereunder. If this provision does not apply to
actions arising
      under the Securities Act or Exchange Act, please tell us how you will
inform investors in
      future filings that the provision does not apply to any actions arising
under the Securities
      Act or Exchange Act.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Ada D. Sarmento at 202-551-3798 or Joe McCann at
202-551-6262 with
any questions.



                                                            Sincerely,
FirstName LastNameNeil F. McFarlane
                                                            Division of
Corporation Finance
Comapany NameAdamas Pharmaceuticals, Inc.
                                                            Office of Life
Sciences
November 20, 2019 Page 2
cc:       Brett White, Esq.
FirstName LastName