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May 11, 2020
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9
CH-1202 Geneva
Switzerland
Re:Addex Therapeutics Ltd.
Post-Effective Amendment No. 1 To Form F-1
Filed April 27, 2020
File No. 333-235554
Dear Mr. Dyer:
            We have reviewed your post-effective amendment and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 the comment, we may have additional comments.
Post-Effective Amendment No. 1 To Form F-1
Incorporation by Reference of Certain Documents, page 159
1.The language in the third sentence of this section suggests that you are incorporating by
reference filings that you will make in the future. Please tell us the bases on which you
rely to forward incorporate by reference or revise.
            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.

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 May 11, 2020 Page 2
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
May 11, 2020
Page 2
            Please contact Chris Edwards at (202) 551-6761 or Celeste Murphy at (202) 551-3257
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.