SEC Company Response from AVADEL PHARMACEUTICALS PLC (AVDL) (CIK 0001012477) — May 8, 2020
AVADEL PHARMACEUTICALS PLC (AVDL) (CIK 0001012477)
Date: May 8, 2020 · CIK: 0001012477 · Accession: 0001104659-20-058802
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File numbers found in text: 333-237962
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CORRESP
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Avadel Pharmaceuticals plc
10 Earlsfort Terrace
Dublin 2, Ireland
D02 T380
May 8, 2020
Via EDGAR Transmission
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: Avadel Pharmaceuticals
plc: Registration Statement on Form S-3 filed May 1, 2020 (File No. 333-237962)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the “Act”), Avadel Pharmaceuticals plc (the “Company”) hereby requests
that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated
to May 12, 2020, at 4:00 pm Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter
LLP, request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration
request, the Company acknowledges that it is aware of its responsibilities under the Act.
If you have any questions regarding this
request, please contact Robert E. Puopolo of Goodwin Procter LLP at (617) 570-1393.
Sincerely,
Avadel Pharmaceuticals plc
/s/ Gregory J. Divis
Gregory J. Divis
Chief Executive Officer and Principal Executive Officer
cc:
Thomas McHugh, Avadel Pharmaceuticals plc
Phillandas Thompson, Avadel Pharmaceuticals plc
Robert E. Puopolo, Esq., Goodwin Procter LLP