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Correspondence 0001104659-26-001751 from Adagene Inc. (ADAG)

Adagene Inc.
Date: Jan. 7, 2026 · CIK: 0001818838 · Accession: 0001104659-26-001751

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File numbers found in text: 333-291196

Date
January 7, 2026
Author
/s/ Peter Luo
Form
CORRESP
Company
Adagene Inc.

Letter

Adagene Inc.

4F, Building C14, No. 218

Xinghu Street, Suzhou Industrial Park

Suzhou, Jiangsu Province,

People's Republic of China

January 7, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Lauren Hamill

Re: Adagene Inc.

Registration Statement on Form F-3

Filed October 31,

File No. 333-291196

Ladies and Gentlemen:

On behalf of Adagene Inc., (the "Company"), and pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the above-referenced Registration Statement on Form F-3 be accelerated so that it will be declared effective at 4:15

p.m. on January 9, 2026, or as soon thereafter as is practicable.

Please direct any questions regarding the foregoing to Xuelin (Steve) Wang at +852 2533-1092 (xuelin.wang@davispolk.com) of Davis Polk & Wardwell LLP, counsel to the Company.

Sincerely,
/s/ Peter Luo

Show Raw Text
CORRESP
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 filename1.htm

 Adagene Inc.

 4F, Building C14, No. 218

 Xinghu Street, Suzhou Industrial Park

 Suzhou, Jiangsu Province,
215123

 People's Republic of China

 January 7, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division
of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:
Ms. Lauren Hamill

 Re: Adagene Inc.

 Registration Statement on Form F-3

 Filed October 31,
2025

 File No. 333-291196

 Ladies and Gentlemen:

 On behalf of Adagene Inc., (the "Company"),
and pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for
the above-referenced Registration Statement on Form F-3 be accelerated so that it will be declared effective at 4:15

 p.m. on January 9, 2026, or as soon thereafter as is practicable.

 Please direct any questions regarding
the foregoing to Xuelin (Steve) Wang at +852 2533-1092 (xuelin.wang@davispolk.com) of Davis Polk & Wardwell LLP, counsel to the Company.

 Sincerely,

 /s/ Peter Luo

 Peter Luo

 Chief Executive Officer

 Adagene Inc.

 cc: Xuelin (Steve) Wang, Esq.