November 14, 2024

Sandra Beaver
Chief Financial Officer
Evolus, Inc.
520 Newport Center Dr.
Suite 1200
Newport Beach, CA 92660

       Re: Evolus, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Form 8-K filed on November 6, 2024
           File No. 001-38381
Dear Sandra Beaver:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
 November 14, 2024
Page 2
Form 10-K for Fiscal Year Ended December 31, 2023
Item 8. Consolidated Financial Statements and Supplementary Data.
Note 2. Basis of Presentation and Summary of Significant Accounting Policies
Inventories , page 73

1.     We note your disclosure that you determine your inventory cost based
upon your
       estimated amount payable to your supplier after accounting for any
reimbursement
       receivable pursuant to the Daewoong Settlement Agreement using the
first-in, first-
       out method with prioritization of the items with the earliest expiration
dates. We note
       similar disclosures within your June 30, 2024 Form 10-Q whereby you
determine cost
       using the first-in, first-out method with prioritization of the items
with the earliest
       expiration dates. Please tell us and revise future filings to explain in
more detail how
       your accounting policy, including the prioritization of items based on
expiration
       dates, complies with the guidance in ASC 330-10-30 and 35.
Form 8-K filed on November 6, 2024
Exhibit 99.1, page 9

2.     We note that you present operating expenses that exclude product cost of
sales
       (excluding amortization of intangible assets) as a non-GAAP measure.
Please tell us
       how you considered the guidance in Question 100.01 the Compliance and
Disclosure
       Interpretations for Non-GAAP Financial Measures since product cost of
sales are
       normal, recurring, cash operating expenses necessary to operate your
business.
        In closing, 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 Tara Harkins at 202-551-3639 or Lynn Dicker at
202-551-3616 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences