April 14, 2020

Arthur J. Higgins
President and Chief Executive Officer
Assertio Holdings, Inc.
100 South Sanders Rd., Suite 300
Lake Forest, IL 60045

       Re: Assertio Holdings, Inc.
           Registration Statement on Form S-4
           Filed April 8, 2020
           File No. 333-237599

Dear Mr. Higgins:

       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 Jeffrey Gabor at 202-551-2544 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:    Todd J. Trattner, Esq.