April 16, 2020

Mike Randolfi
Chief Financial Officer
Adtalem Global Education Inc.
500 West Monroe Street
Chicago, Illinois 60661

       Re: Adtalem Global Education Inc.
           Form 10-K for the Fiscal Year Ended June 30, 2019
           Filed August 28, 2019
           File No. 001-13988

Dear Mr. Randolfi:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended June 30, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Other Contractual Arrangements, page 74

1.    It appears the cash interest payments on your debt obligations may
represent a material
      contractual obligation. Because this table is aimed at increasing
transparency of cash flow,
      we believe these payments should be included in the table or disclosed in
the footnotes
      using the same time frames stipulated in the table. Please also disclose
any assumptions
      you made to derive these amounts. If you choose not to include these
payments, a footnote
      to the table should clearly identify the excluded item and provide any
additional
      information that is material to an understanding of your cash
requirements. Refer to
      Item 303(a)(5)303(a)(5) of Regulation S-K and footnote 46 to SEC Release
No. 33-8350.
 Mike Randolfi
Adtalem Global Education Inc.
April 16, 2020
Page 2
Item 8. Financial Statement and Supplementary Data
Note 4. Summary of Significant Accounting Policies
Revenue Recognition , page 88

2.       We note that for Becker test preparation revenue is recognized when
access to the course
         materials is delivered to the customer and that for Adtalem Brazil and
EduPristine test
         preparation course instruction revenue is recognized on a
straight-line basis over the
         applicable instruction delivery periods. Please tell us in further
detail why the revenue
         recognition method for the test preparation services differs between
Becker and Adtalem
         Brazil and EduPristine. In this regard, we note from the Becker
website that Premium and
         Pro packages include various live online and/or live courses, success
coaching, and
         personal tutoring in addition to pre-packaged course materials.

       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.

       You may contact Aamira Chaudhry at 202-551-3389 or Lyn Shenk at
202-551-3380 with
any questions.



FirstName LastNameMike Randolfi                              Sincerely,
Comapany NameAdtalem Global Education Inc.
                                                             Division of
Corporation Finance
April 16, 2020 Page 2                                        Office of Trade &
Services
FirstName LastName