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July 10, 2023

  Re:
  Adagene Inc.

  Annual Report on Form 20-F

  Filed April 28, 2023

  File No. 001-39997

Ms. Lynn
Dicker

Mr. Kevin Kuhar

Mr. Kyle Wiley

Mr. Christopher Dunham

Mr. Jimmy McNamara

Mr. Tim Buchmiller

Office of Life Sciences

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Dear Lynn
Dicker, Kevin Kuhar, Kyle Wiley, Christopher Dunham, Jimmy McNamara and Tim Buchmiller:

This letter sets forth the supplemental responses of Adagene Inc. (“Adagene”
or the “Company”) to the comments (the “Comments”) the Company received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) in a letter dated June 5, 2023 (the “June Response
Letter”) in connection with a teleconference between the Staff and the Company’s counsel on July 5, 2023. Capitalized
terms used but not otherwise defined in this supplemental response letter shall have the meanings ascribed to such terms in the June Response
Letter.

For your convenience, we have included herein the comment in bold,
and the Company’s responses are set forth immediately below the Comment.

*          *          *          *

General Note to the Staff:

The Company
respectfully submits in this letter its proposed updates to the disclosures contained in the annual report for the year ending
December 31, 2022 (the “2022 Annual Report”), which, subject to the Staff’s review and further regulatory
developments (if applicable), will be included in the Company’s annual report for the year ending December 31, 2023 (the “2023
Annual Report”) and future filings, to the extent applicable.

Annual Report on Form 20-F for the fiscal year ended December 31,
2022

Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 212

1. We note your statement that you reviewed your register of members and public filings made by your shareholders in connection with
your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and tell us whether
you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. In your response,
please provide a similarly detailed discussion of the materials reviewed and legal opinions or third party certifications relied upon
in connection with the required disclosures under paragraphs (b)(2) and (3).

Required disclosures under paragraph (b)(2) of Item 16I

With respect to the percentage of shares of Adagene Inc. owned by governmental
entities in the foreign jurisdiction in which the registrant is incorporated or otherwise organized, namely, Cayman Islands, Hong Kong,
PRC, United States, Australia, and Switzerland, and Singapore, the Company examined the Company’s register of members
and Public Filings made by the Company’s shareholders as the Company explained under the subsection titled “Submission under
paragraph (a) of Item 16I” of the response to Comment No. 1 in the June Response Letter. Other than
reviewing the Public Filings made by the Company’s shareholders, the Company was unable to conduct look-through exercises of the
beneficial ownership of holders of its American deposited shares to determine whether such holders are owned by governmental entities
in the foreign jurisdiction in which the registrant is incorporated or otherwise organized. However, nothing comes to the attention of
the Company that makes the Company believe that any such holder is owned by governmental entities in the foreign jurisdiction in which
the registrant is incorporated or otherwise organized.

With respect to the percentage of shares of each of the Company’s
consolidated foreign operating entities as disclosed in Exhibit 8.1, because each such consolidated foreign operating entity is directly
wholly-owned by its respective shareholder, which is also a consolidated foreign operating entity of the Company, and indirectly wholly-owned
by Adagene Inc., the Company did not need to review other documentation to reach its conclusion.

Required disclosures under paragraph (b)(3) of Item 16I

For similar reasons, the Company examined the Company’s register
of members and Public Filings made by the Company’s shareholders to reach the conclusion with respect to whether the governmental
entities in the applicable foreign jurisdiction with respect to the Company’s registered public accounting firm have a controlling
financial interest in each of Adagene Inc.

For similar reasons, the Company did not need to review other documentation
to reach its conclusion with respect to each of its consolidated foreign operating entity.

***

If you have
further questions or comments regarding, or require further information or clarification of, any of the responses provided in this letter
or if the Commission has any questions with respect to Adagene’s Annual Report on Form 20-F, please contact Xuelin (Steve)
Wang at +852 2533-1092 (xuelin.wang@davispolk.com) of Davis Polk & Wardwell LLP.

Thank you for your time and attention.

  Yours sincerely,

  /s/ Raymond Tam

  Name: Raymond Tam

  Title: Chief Financial Officer

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  cc:
  Dr. Peter Luo, Chief Executive Officer

Adagene Inc.

  Mr. Xuelin (Steve) Wang, Ph.D. Partner

Davis Polk & Wardwell LLP

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