May 21, 2025

Peter Luo
Chief Executive Officer
Adagene Inc.
4F, Building C14, No. 218
Xinghu Street, Suzhou Industrial Park
Suzhou, Jiangsu Province, 215123
People   s Republic of China

       Re: Adagene Inc.
           Registration Statement on Form F-3
           Filed May 9, 2025
           File No. 333-287161
Dear Peter Luo:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Registration Statement on Form F-3
General

1.     Please revise the first bullet of the Explanatory Note to reflect the
inclusion of resale
       shares to be offered by selling shareholders in the base prospectus.
Cover Page

2.     We note that your base prospectus covers the offering of up to $200
million of
       ordinary shares, warrants or units to be offered by you or selling
shareholders. Please
       revise your cover page to quantify the number of ordinary shares that
may be offered
       by the selling shareholders. Please also revise your disclosure, where
appropriate,
       to identify the selling shareholders and provide a brief description of
the initial
 May 21, 2025
Page 2

       transaction in which these securities were sold to the selling
shareholders. Refer to
       Item 501 of Regulation S-K and General Instruction II.H of Form F-3 for
guidance.
       We note that you do not appear to qualify for the omission of this
information under
       Rule 430B(b) because the company is not primarily eligible to use Form
F-3 under
       General Instruction I.B.1.
        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 Tyler Howes at 202-551-3370 or Laura Crotty at
202-551-7614 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Xuelin Wang, Esq.