SecProbe.io

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 filename1.htm

 December 3, 2025

 VIA EDGAR

 Office of Life Sciences

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

 Attention: Mr. Chris Edwards

 Re:
 Addex Therapeutics Ltd

 Acceleration Request for Registration Statement on Form F-3

 File No. 333-291644

 Acceleration Request

 Requested Date:
 December 5, 2025

 Requested Time:
 4:15 p.m., Eastern Time

 Dear Mr. Edwards:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended
(the " Act "), Addex Therapeutics Ltd (the " Company ") hereby requests that the effective date of the
above-referenced registration statement (the " Registration Statement ") be accelerated to December 5, 2025, at
4:15 p.m., 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.

 Once the Registration Statement is effective, please orally confirm
the event with our counsel, Goodwin Procter LLP, by calling Kristopher Brown at (212) 813-8821.

 If you have any questions regarding this request, please contact Kristopher
Brown of Goodwin Procter LLP at (212) 813-8821.

 Sincerely,

 ADDEX THERAPEUTICS LTD

 /s/ Tim Dyer

 Tim Dyer

 Chief Executive Officer

 cc:

 Kristopher Brown, Esq., Goodwin Procter LLP
 Justin Platt, Esq., Goodwin Procter LLP

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Addex Therapeutics
Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

June 1, 2023 Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Alan Campbell

            Tyler
Howes

 RE: Addex Therapeutics Ltd

                                            Registration Statement on Form F-1

                                            File No. 333-271611

Acceleration Request

 Requested Date: June 2,
                                            2023

  Requested Time: 4:00 P.M. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the Securities
and Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form F-1 (File No. 333-271611)
(the “Registration Statement”) to become effective on June 2, 2023, at 4:00 p.m., Eastern Time, or as
soon thereafter as is practicable.

Once the Registration Statement has been declared
effective, please orally confirm that event with Josh Kaufman, counsel to the Registrant, at (212) 479-6495.

Very truly yours,

Addex Therapeutics Ltd.

/s/ Tim Dyer

Tim Dyer

Chief Executive Officer

cc: Josh Kaufman, Cooley LLP

  Marc Recht, Cooley LLP

  David C. Boles, Cooley (UK) LLP

  Frank Gerhard, Homburger AG

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Addex Therapeutics
Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

    May 12, 2023
    Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Attn: Alan Campbell

 RE: Addex Therapeutics Ltd

Withdrawal
of Acceleration Request

Registration Statement on Form F-1

File No. 333-271611

Dear Mr. Campbell:

Reference is made to our letter, filed as correspondence
via EDGAR on May 11, 2023, in which we requested the acceleration of the effective date of the above-referenced Registration Statement
for Friday, May 12, 2023, at 4:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are
no longer requesting that such Registration Statement be declared effective at this time, and we hereby formally withdraw our request
for acceleration of the effective date.

    Very truly yours,

    Addex Therapeutics Ltd.

    /s/ Tim Dyer

    Tim Dyer

    Chief Executive Officer

 cc: Josh Kaufman, Cooley LLP

Marc Recht, Cooley
LLP

David C. Boles, Cooley (UK) LLP

Frank Gerhard, Homburger AG

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Addex Therapeutics
Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

May 11, 2023 Via
Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Alan Campbell

 RE: Addex Therapeutics Ltd

Registration Statement on Form F-1

File No. 333-271611

Acceleration Request

Requested Date:	     May 12,
2023

Requested Time:	    4:00
P.M. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the Securities and
Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form F-1 (File No. 333-271611)
(the “Registration Statement”) to become effective on May 12, 2023, at 4:00 p.m., Eastern Time, or as soon
thereafter as is practicable.

Once the Registration Statement has been declared
effective, please orally confirm that event with Josh Kaufman, counsel to the Registrant, at (212) 479-6495.

Very truly yours,

Addex Therapeutics Ltd.

/s/ Tim Dyer

Tim Dyer

Chief Executive Officer

cc: Josh Kaufman, Cooley LLP

  Marc Recht, Cooley LLP

  David C. Boles, Cooley (UK) LLP

  Frank Gerhard, Homburger AG

United States securities and exchange commission logo
May 9, 2023
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Registration Statement on Form F-1
Filed May 3, 2023
File No. 333-271611
Dear Tim Dyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Alan Campbell at 202-551-4224 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman

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Addex Therapeutics
Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

August 25, 2022  Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Michael Davis

    Celeste Murphy

 RE: Addex Therapeutics Ltd

Registration Statement on Form F-1

File No. 333-266995

Acceleration Request

    Requested Date:
    August 29, 2022

    Requested Time:
    4:00 P.M. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the Securities and
Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form F-1 (File No. 333-266995) (the
“Registration Statement”) to become effective on August 29, 2022, at 4:00 p.m., Eastern Time, or as soon thereafter
as is practicable.

Once the Registration Statement has been declared
effective, please orally confirm that event with Josh Kaufman, counsel to the Registrant, at (212) 479-6495.

Very truly yours,

Addex Therapeutics Ltd.

    /s/ Tim Dyer

    Tim Dyer

    Chief Executive Officer

    cc:
     Josh Kaufman, Cooley LLP

    Marc Recht, Cooley LLP
 David C. Boles, Cooley (UK) LLP

    Frank Gerhard, Homburger AG

United States securities and exchange commission logo
August 25, 2022
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Registration Statement on Form F-1
Filed August 19, 2022
File No. 333-266995
Dear Mr. Dyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Tyler Howes at 202-551-3370 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.

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    Joshua A. Kaufman
    Via EDGAR

    +1 212 479 6495

    josh.kaufman@cooley.com

March 29, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:           Chris
Edwards

 Re: Addex Therapeutics Ltd

Post Effective Amendment No. 1 to Form F-1

Filed April 27, 2020

File No. 333-235554

Ladies and Gentlemen:

On behalf of Addex Therapeutics Ltd (the “Company”),
we are providing this letter in response to your letter (the “Letter”) received from the staff of the U.S. Securities
and Exchange Commission’s Division of Corporation Finance (the “Staff”), dated February 1, 2022,
with respect to the Company’s Post-Effective Amendment No.1 to the Registration Statement on Form F-1, filed on April 27,
2020 (the “Registration Statement”).

Set forth below is the Company’s response
to the Letter. We have incorporated the contents of the Letter into this response letter in italics for your convenience.

 1. It has been more than nine months since you filed this registration statement and it is now out of
date. Within 30 days from the date of this letter, you should either:

 • Amend it to comply with the applicable requirements
of the Securities Act of 1933, the rules and regulations under the Act, and the requirements of the form; or

 • File a request for withdrawal.

Response: The Company respectfully
advises the Staff that it has complied with the Staff’s comment and has filed Post-Effective No. 2 to the Registration Statement
in order to remove from registration any securities which remain unsold at the termination of the offering.

*	     *	     *

Please contact me at (212) 479 6495 with any questions or further comments
regarding our response to the Staff’s Comment.

Cooley LLP 55 Hudson Yards
New York, NY 10001

t: (212) 479-6000 f: (212)
479-6275 cooley.com

United States Securities and Exchange Commission

March 29, 2022

Page Two

Sincerely,

/s/ Joshua A. Kaufman

Joshua A. Kaufman

cc:          Timothy Dyer, Addex Therapeutics
Ltd

       Marc Recht, Cooley LLP

Cooley LLP 55 Hudson Yards
New York, NY 10001

t: (212) 479-6000 f: (212)
479-6275 cooley.com

United States securities and exchange commission logo
January 14, 2022
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Registration Statement on Form F-1
Filed January 7, 2022
File No. 333-262050
Dear Mr. Dyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Michael Davis at 202-551-4385 or Celeste Murphy at 202-551-3257 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman

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Addex Therapeutics
Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

    January 14, 2022
    Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael Davis

Celeste Murphy

RE: Addex Therapeutics Ltd

Registration Statement on Form F-1

File No. 333-262050

Acceleration Request

Requested Date:           January 18,
2022

Requested Time:           4:00 P.M. Eastern
Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the Securities and
Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form F-1 (File No. 333-262050) (the
“Registration Statement”) to become effective on January 18, 2022, at 4:00 p.m., Eastern Time, or as soon thereafter
as is practicable.

Once the Registration Statement has been declared
effective, please orally confirm that event with Josh Kaufman, counsel to the Registrant, at (212) 479-6495.

Very truly yours,

Addex Therapeutics Ltd.

/s/ Tim Dyer

Tim Dyer

Chief Executive Officer

cc: Josh Kaufman, Cooley LLP

Marc Recht, Cooley LLP

David C. Boles, Cooley (UK) LLP

Frank Gerhard, Homburger AG

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Addex Therapeutics Ltd

Chemin des Mines 9,

CH-1202 Geneva, Switzerland

April 12, 2021

VIA   EDGAR

United States Securities and Exchange Commission
 Division of Corporation Finance
 100 F Street, N.E.
 Washington, D.C. 20549
 Attn:  Jane Park

RE:                          Addex Therapeutics Ltd
 Registration Statement on Form F-3
 File No. 333-255089

Acceleration Request

Requested Date:                              April 13, 2021

Requested Time:                          4:00 P.M. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the Securities and Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form F-3 (File No. 333-255089) (the “Registration Statement”) to become effective on April 13, 2021, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable.

Once the Registration Statement has been declared effective, please orally confirm that event with Josh Kaufman, counsel to the Registrant, at (212) 479-6495.

Very truly yours,

Addex Therapeutics Ltd

/s/ Tim Dyer

Tim Dyer

Chief Executive Officer

cc:                                Josh Kaufman, Cooley LLP

Marc Recht, Cooley LLP

David C. Boles, Cooley (UK) LLP

Frank Gerhard, Homburger AG

United States securities and exchange commission logo
April 9, 2021
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd
Chemin des Mines 9
CH-1202 Geneva, Switzerland
Re:Addex Therapeutics Ltd
Registration Statement on Form F-3
Filed April 7, 2021
File No. 333-255089
Dear Mr. Dyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jane Park at 202-551-7439 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua Kaufman, Esq.

United States securities and exchange commission logo
February 1, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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:
            It has been more than nine months since you filed this registration statement and it is now
out of date.  Within 30 days from the date of this letter, you should either:
•amend it to comply with the applicable requirements of the Securities Act of 1933, the rules
and regulations under the Act, and the requirements of the form; or
•file a request for withdrawal.
            If you requested confidential treatment for portions of any exhibits to your registration
statement and you request withdrawal of that registration statement, please submit a concurrent
request for withdrawal of your application for confidential treatment.
            If you do not amend the registration statement or file a request for withdrawal (or provide
us with a satisfactory explanation of why you have not done either) within 30 days, we may enter
an order declaring the registration statement abandoned under rule 479 of the Act.
            Please contact Chris Edwards at 202-551-6761 with any questions.
Sincerely,

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 February 1, 2021 Page 2
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
February 1, 2021
Page 2
Division of Corporation Finance
Office of Life Sciences

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January 5, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re:

Addex Therapeutics Ltd

Registration Statement on Form F-1 (Registration   No. 333-251322), as amended - Concurrence in Acceleration Request

Ladies and Gentlemen:

H.C. Wainwright & Co., LLC (“Wainwright”), as underwriter for the referenced offering, pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), hereby concurs in the request by Addex Therapeutics Ltd that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to 5:15 P.M. (Eastern Time), or as soon as practicable thereafter, on January 6, 2021, or at such later time as the Registrant or its outside counsel, Cooley LLP, may orally request by telephone call to the staff that such Registration Statement be declared effective. Wainwright affirms that it is aware of its obligations under the Securities Act in connection with this offering.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

Wainwright hereby represents that it is acting in compliance and will act in compliance with the provisions of Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above proposed offering.

Very truly yours,

H.C. WAINWRIGHT & CO.,   LLC

By:

/s/ Edward D. Silvera

Name: Edward D. Silvera

Title: Chief Operating   Officer

430 Park Avenue | New York, New York 10022 | 212.356.0500
  Security services provided by H.C. Wainwright & Co., LLC | Member: FINRA/SIPC

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ADDEX THERAPEUTICS LTD

Chemin des Mines 9

CH-1202 Geneva, Switzerland

January 5, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn:       Chris Edwards

RE:                          Addex Therapeutics Ltd
 Registration Statement on Form F-1
 File No. 333-251322

Ladies and Gentlemen:

Addex Therapeutics Ltd (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form F-1 to become effective on January 6, 2021 at 5:15 p.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission.  The Registrant hereby authorizes each of Josh Kaufman and David Boles of Cooley LLP, counsel to the Registrant, to make such request on its behalf.

Once the Registration Statement has been declared effective, please orally confirm that event with Josh Kaufman of Cooley LLP, counsel to the Registrant, at (212) 479-6495, or in his absence, David Boles at +44 (0) 20 7556 4446.

[SIGNATURE PAGE FOLLOWS]

   Very   truly yours,

   ADDEX   THERAPEUTICS LTD

By:

/s/   Tim Dyer

Name:

Tim Dyer

Title:

Chief Executive Officer

cc:                                Josh Kaufman, Cooley LLP

David Boles, Cooley LLP

Marc Recht, Cooley LLP

Rick Werner, Haynes and Boone, LLP

Matt Fry, Haynes and Boone, LLP

[COMPANY SIGNATURE PAGE TO ACCELERATION REQUEST]

United States securities and exchange commission logo
October 15, 2020
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9
CH-1202 Geneva
Switzerland
Re:Addex Therapeutics Ltd.
Draft Registration Statement on Form F-1
Submitted on October 13, 2020
CIK No. 0001574232
Dear Mr. Dyer:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.
            Please contact Chris Edwards at (202) 551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.

United States securities and exchange commission logo
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.

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Addex Therapeutics Ltd

Chemin Des Mines 9

CH 1202 Geneva, Switzerland

VIA EDGAR

January 23, 2020

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:                 Ada D. Sarmento

Mary Beth Breslin

Re:                             Addex Therapeutics Ltd

Acceleration Request for Registration Statement on Form F-1

File No. 333-235554

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Addex Therapeutics Ltd (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to January 27, 2020, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Cooley 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.

Once the Registration Statement is effective, please orally confirm the event with our counsel, Cooley LLP, by calling Joshua A. Kaufman at (212) 479-6495.

If you have any questions regarding this request, please contact Joshua A. Kaufman of Cooley LLP at (212) 479-6495. Thank you for your assistance with this matter.

Sincerely,

ADDEX THERAPEUTICS LTD

/s/ Tim Dyer

Tim Dyer

Chief Executive Officer

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Joshua A.   Kaufman

Via EDGAR

+1 212 479 6495

josh.kaufman@cooley.com

January 23,   2020

U.S. Securities   and Exchange Commission

Division of   Corporation Finance

Office of Life   Sciences

100 F Street,   N.E.

Washington, D.C.   20549

Attention:                                      Vanessa Robertson

Lisa Vanjoske

Ada D. Sarmento

Mary Beth Breslin

Re:     Addex Therapeutics Ltd

Registration Statement on Form F-1

Filed on December 17, 2019 and amended on January 13, 2020 and January 23, 2020 No. 333-235554

Ladies and Gentlemen:

On behalf of Addex Therapeutics Ltd (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated January 15, 2020 with respect to the Company’s Registration Statement on Form F-1 (No. 333-235554), filed with the Commission on December 17, 2019 (the “Initial Filing”) and amended on January 13, 2020 and January 23, 2020 (“Amendment No. 2” and, together with the Initial Filing and the prior amendments, the “Registration Statement”). The Company is concurrently publicly filing Amendment No. 2 to the Filed Registration Statement (“Amendment No. 2”), which includes changes that reflect the Company’s response to the Comment as well as certain other updates. Set forth below is the Company’s response to the Comment. For your convenience, we have incorporated into this response letter the Comment in italics. The page reference in the text of the Company’s response corresponds to the page number in Amendment No. 2.

Amendment No. 1 to Registration Statement on Form F-1

Compensation of Directors and Executive Management, page 103

1.              Please revise this section to include compensation information for fiscal year 2019, the last full financial year. Refer to Item 6.B of Form 20-F.

Response: In response to the Comment, the Company has revised the disclosure on pages 103, 104 and 105 to include compensation information for fiscal year 2019.

*                                         *                                         *

Cooley LLP 55 Hudson Yards New York, NY 10001
 t: (212) 479-6000 f: (212) 479-6275 cooley.com

Please contact me at (212) 479 6495 with any questions or further comments regarding our responses to the Comment.

Sincerely,

/s/ Joshua A. Kaufman

Joshua A. Kaufman

cc:                                Timothy Dyer, Addex Therapeutics Ltd

2

January 15, 2020
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed January 14, 2020
File No. 333-235554
Dear Mr. Dyer:
            We have reviewed your amended registration statement 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 this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Compensation of Directors and Executive Management, page 103
1.Please revise this section to include compensation information for fiscal year 2019, the
last full financial year. Refer to Item 6.B of Form 20-F.
            You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at 202-551-3614
if you have questions regarding comments on the financial statements and related
matters.  Please contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-
3625 with any other questions.

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 January 15, 2020 Page 2
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
January 15, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.

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Joshua A. Kaufman

+1 212 479 6495

josh.kaufman@cooley.com

Via   EDGAR

January 13, 2020

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attention:                                         Vanessa Robertson

Lisa Vanjoske

Ada D. Sarmento

Mary Beth Breslin

Re:           Addex Therapeutics Ltd
 Registration Statement on Form F-1
 Filed on December 17, 2019 and amended on January 13, 2020
 No. 333-235554

Ladies and Gentlemen:

On behalf of Addex Therapeutics Ltd (the “Company”), we are providing this letter in response to the comment (the “Comment”) received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated December 31, 2019 with respect to the Company’s Registration Statement on Form F-1 (No. 333-235554), as filed with the Commission on December 17, 2019 (the “Filed Registration Statement”). The Company is concurrently publicly filing Amendment No. 1 to the Filed Registration Statement (“Amendment No. 1”), which includes changes that reflect the Company’s response to the Comment as well as certain other updates. Set forth below is the Company’s response to the Comment. For your convenience, we have incorporated into this response letter the Comment in italics. The page reference in the text of the Company’s response corresponds to the page number in Amendment No. 1.

Registration Statement on Form F-1

Collaboration Agreement with Indivior, page 83

1.              We note your revised disclosure in response to our prior comment 5 that you are eligible for a royalty on net sales of applicable products on a country-by-country basis. Please revise your disclosure in this section to provide the royalty term.

Response: In response to the Comment, the Company has revised the disclosure on page 83 of Amendment No. 1 to disclose the royalty term of the Company’s agreement with Indivior.

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Cooley LLP   55 Hudson Yards   New York, NY   10001
 t: (212) 479-6000  f: (212) 479-6275  cooley.com

Please contact me at (212) 479 6495 with any questions or further comments regarding our responses to the Comment.

Sincerely,

/s/   Joshua A. Kaufman

Joshua   A. Kaufman

cc:                                Timothy Dyer, Addex Therapeutics Ltd

2

December 31, 2019
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Registration Statement on Form F-1
Filed December 17, 2019
File No. 333-235554
Dear Mr. Dyer:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1
Collaboration Agreement with Indivior, page 83
1.We note your revised disclosure in response to our prior comment 5 that you are eligible
for a royalty on net sales of applicable products on a country-by country-basis.  Please
revise your disclosure in this section to provide the royalty term.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 December 31, 2019 Page 2
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
December 31, 2019
Page 2
statement.
            You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at 202-551-3614
if you have questions regarding comments on the financial statements and related
matters.  Please contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-
3625 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.

CORRESP
1
filename1.htm

Joshua A. Kaufman

Via EDGAR

+1 212 479 6495

josh.kaufman@cooley.com

December 17, 2019

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attention:                                         Vanessa Robertson

Lisa Vanjoske

Ada D. Sarmento

Mary Beth Breslin

Re:           Addex Therapeutics Ltd
 Registration Statement on Form F-1
 Filed on December 17, 2019
 CIK No. 0001574232

Ladies and Gentlemen:

On behalf of Addex Therapeutics Ltd (the “Company”), we are providing this letter in response to comments (the “Comments”) received from the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) by letter dated December 11, 2019 with respect to the Company’s Amendment No.1 to the Draft Registration Statement on Form F-1, as confidentially submitted to the Staff on November 27, 2019. The Company is concurrently publicly filing the Registration Statement on Form F-1 (the “Filed Registration Statement”), which includes changes that reflect the responses to the Comments as well as certain other updates. Set forth below are the Company’s responses to the Comments. The numbering of the paragraphs below corresponds to the numbering of the Comments, which for your convenience we have incorporated into this response letter in italics. Page references in the text of the Company’s responses correspond to the page numbers in the Filed Registration Statement. Capitalized terms used in this letter but not otherwise defined in this letter have the meanings assigned to them in the Filed Registration Statement.

Amendment No.1 to the Draft Registration Statement on Form F-1

Prospectus Summary, page 1

1.              We note your response to our prior comment 3 and continue to object to your characterization of your product candidates as “first-in-class.”  The qualifier, “subject to regulatory approval,” does not address our concerns that “first-in-class” continues to imply that the product will be effective, and is likely to be the first treatment available, neither of which is appropriate at this stage of development.  Please revise your registration statement to remove the phrase “first-in-class.”  Additionally, you may state that your product candidate is the first orally available mGlu5 NAM for the treatment of PD-LID, if accurate. However, you may not imply that your product will be the first product in this class available.

Response: In response to the Staff’s comment, the Company has deleted all references to “first-in-class” in respect of its product candidates on pages 3, 42, 61, 64, 65 and 66 of the Filed Registration Statement.

Cooley LLP   55 Hudson Yards   New York, NY   10001
 t: (212) 479-6000  f: (212) 479-6275  cooley.com

Internally Developed Product Candidates, page 2

2.              We note your disclosure that an increasing placebo response “confounded significance” at Day 28 of your Phase 2a proof of concept clinical trial of dipraglurant in PD-LID.  Please revise your disclosure to explain what you mean by “confounded significance.”

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 3, 69 and 70 of the Filed Registration Statement to replace the phrase “confounded significance” with “resulted in the effect of dipraglurant on PD-LID clinical symptoms of not showing statistical significance.”

Business

Our Platform and Competitive Positioning in Allosteric Modulation, page 64

3.              We note your disclosure that your leadership position in GABAB PAM was recognized in 2018 by your strategic partnership with Indivior.  Please substantiate this statement or revise it to make it clear that this is management’s belief.

Response: In response to the Staff’s comment, the Company has revised the disclosure on page 65 of the Filed Registration Statement to remove the above statement.

Dipraglurant for the treatment of Parkinson’s disease levodopa induced dyskinesia (PD-LID), page 67

4.              We note your response to our prior comment 9.  Please revise your disclosure in this section to include the explanation provided in your response.

Response: In response to the Staff’s comment, the Company has revised the disclosure on page 67 of the Filed Registration Statement to include the explanation provided in its response to prior comment 9.

Material Agreements, page 83

5.              We note your revisions in your registration statement in this section, but we do not see revisions responsive to our prior comment 16.  For both material agreements discussed in this section, please disclose the duration of the agreement, the royalty term and the termination provisions.

Response: In response to the Staff’s comment, the Company has revised disclosure on pages 83 and 84 of the Filed Registration Statement to specify in greater detail the duration of the material agreements, the royalty terms and termination provisions.

2

Intellectual Property

Patents and Proprietary Rights, page 84

6.              We note your revisions in response to our prior comment 17 and reissue.  Please revise your disclosure to name the specific jurisdictions where you have granted patents as opposed to simply stating Europe or other international jurisdictions.

Response: In response to the Staff’s comment, the Company has revised the disclosure on page 85 of the Filed Registration Statement to indicate the specific jurisdictions in which it has been granted patents.

Financial Statements

Notes to Financial Statements

13. Revenue from contract with customer

License & research agreement with Indivior PLC, page F-49

7.              Refer to your response to comment 19. Please expand your disclosure in the footnotes similar to your revisions on page 44 to clarify that the first distinct performance obligation is the selected compound ADX71441 which falls within the definition of a licensed compound, whose rights of use and benefits thereon was transferred in January 2018.

Response: In response to the Staff’s comment, the Company has expanded the disclosures on pages F-17, F-18 and F-50 of the financial statements to clarify that the first distinct performance obligation is the selected compound ADX71441, which falls within the definition of a licensed compound and whose rights of use and benefits thereon was transferred in January 2018. We have made certain structural changes to the disclosure to present the details in a more understandable way to the reader.

*                                         *                                         *

Please contact me at (212) 479 6495 with any questions or further comments regarding our responses to the Staff’s Comments.

Sincerely,

/s/   Joshua A. Kaufman

Joshua   A. Kaufman

cc:                                Timothy Dyer, Addex Therapeutics Ltd

3

December 11, 2019
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted November 27, 2019
CIK No. 0001574232
Dear Mr. Dyer:
            We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary, page 1
1.We note your response to our prior comment 3 and continue to object to your
characterization of your product candidates as "first-in-class."  The qualifier, "subject to
regulatory approval," does not address our concerns that "first-in-class" continues to imply
that the product will be effective, and is likely to be the first treatment available, neither of
which is appropriate at this stage of development.  Please revise your registration
statement to remove the phrase "first-in-class."  Additionally, you may state that your
product candidate is the first orally available mGlu5 NAM for the treatment of PD-LID, if
accurate. However, you may not imply that your product will be the first product in this

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 December 11, 2019 Page 2
 FirstName LastNameTim Dyer
Addex Therapeutics Ltd.
December 11, 2019
Page 2
class available.
Internally Developed Product Candidates, page 2
2.We note your disclosure that an increasing placebo response "confounded significance" at
Day 28 of your Phase 2a proof of concept clinical trial of dipraglurant in PD-LID.  Please
revise your disclosure to explain what you mean by "confounded significance."
Business
Our Platform and Competitive Positioning in Allosteric Modulation, page 64
3.We note your disclosure that your leadership position in GABAB PAM was recognized in
2018 by your strategic partnership with Indivior.  Please substantiate this statement
or revise it to make it clear that this is management's belief.
Dipraglurant for the treatment of Parkinson's disease levodopa induced dyskinesia (PD-LID),
page 67
4.We note your response to our prior comment 9.  Please revise your disclosure in this
section to include the explanation provided in your response.
Material Agreements, page 83
5.We note your revisions in your registration statement in this section, but we do not see
revisions responsive to our prior comment 16.  For both material agreements discussed in
this section, please disclose the duration of the agreement, the royalty term and the
termination provisions.
Intellectual Property
Patents and Proprietary Rights, page 84
6.We note your revisions in response to our prior comment 17 and reissue.  Please revise
your disclosure to name the specific jurisdictions where you have granted patents as
opposed to simply stating Europe or other international jurisdictions.
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
13. Revenue from contract with customer
License & research agreement with Indivior PLC, page F-49
7.Refer to your response to comment 19. Please expand your disclosure in the footnotes
similar to your revisions on page 44 to clarify that the first distinct performance obligation
is the selected compound ADX71441 which falls within the definition of a licensed
compound, whose rights of use and benefits thereon was transferred in January 2018.
            You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at 202-551-3614
if you have questions regarding comments on the financial statements and related

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 December 11, 2019 Page 3
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
December 11, 2019
Page 3
matters.  Please contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-
3625 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.

October 23, 2019
Tim Dyer
Chief Executive Officer
Addex Therapeutics Ltd.
Chemin des Mines 9,
CH-1202 Geneva,
Switzerland
Re:Addex Therapeutics Ltd.
Draft Registration Statement on Form F-1
Submitted September 24, 2019
CIK No. 0001574232
Dear Mr. Dyer:
            We have reviewed your draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
Cover Page
1.We note your disclosure that the last reported sale price of your ordinary shares on SIX
was CHF 1.51 per share, equivalent to $ 1.47 per share or $__ per ADS. You may use the
most recent home market trading price, converted to U.S. dollars at the most recent
exchange rate, assuming the U.S. IPO price will be substantially similar to the home
market trading price. If you expect that the U.S. IPO price will not be substantially similar
to the home market trading price, please disclose on the prospectus cover page a bona fide
price range of the offered securities. If you intend to price the securities based on the
SIX market price, you may disclose a percentage range based on that price (for example,

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 October 23, 2019 Page 2
 FirstName LastNameTim Dyer
Addex Therapeutics Ltd.
October 23, 2019
Page 2
10% of the home market price) within which you intend to price the securities. See Item
501(b)(3) of Regulation S-K.
Prospectus Summary, page 1
2.The prospectus summary should include a balanced presentation of your business,
including your competitive position in the industry. Given the current state of
development of your product candidates, it does not appear that you have a basis for your
statement that you have a "leading position in allosteric modulation" and other similar
statements of leadership throughout the prospectus.  Please revise.  Also balance your
summary by providing equally prominent disclosure about the competitive and regulatory
challenges you face.
3.Please revise your statements here and elsewhere in the prospectus that certain of your
product candidates are potentially "first-in-class" and "best-in-class." These statements
imply an expectation of regulatory approval and are inappropriate given the length of time
and uncertainty with respect to securing marketing approval.
Product Pipeline, page 2
4.Your pipeline appears to include every in-house development program as well as certain
programs that are licensed to other entities for development. Please revise the table to
include only those programs that are material to the company.  If you believe that every
program listed is material, please provide us with an analysis explaining your belief.  In
particular, to the extent that your programs in the lead optimization stage are material to
the company, please discuss this in your analysis. Please also revise to limit your pipeline
table to product candidates in which you have a role in developing or commercializing.
5.We note several references to statistically significant results here and elsewhere in the
prospectus. Please explain whether statistical significance is relevant to the
evidentiary standards for drug approval in the jurisdictions where you seek approval of
your product candidates.
6.We note your disclosure that Janssen has announced that ADX71149 demonstrated
synergistic efficacy with levetiracetam in preclinical models of epilepsy.  Please explain
what is meant by "synergistic efficacy." We also note your statements on page 73 that
your GABAB PAM drug candidates have demonstrated "excellent preclinical efficacy"
and have also "proven efficacy."  Efficacy is a determination that is solely within the
authority of the FDA or similar foreign regulators. You may present clinical trial end
points and objective data resulting from trials without concluding efficacy.  Please revise
these statements.
Implications of Being an Emerging Growth Company and a Foreign Private Issuer, page 6
7.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 October 23, 2019 Page 3
 FirstName LastNameTim Dyer
Addex Therapeutics Ltd.
October 23, 2019
Page 3
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
Business, page 53
8.We note your disclosure in this section that your Phase 2a proof of concept clinical trial of
dipraglurant in PD-LID "illustrated safety" and that dipraglurant exhibited an "acceptable
safety profile" in a clinical trial.  Safety is a determination that is solely within the
authority of the FDA or similar foreign regulators.  You may state that your product
candidates have been well tolerated if true.  Please revise such statements.
Our Product Candidates
Dipraglurant, page 61
9.Please explain what you mean by your registration clinical trial for dipraglurant will be
"fully powered."
10.Please disclose the source for the information regarding levodopa in Figure 1 on page 62.
Outcome Measures, page 64
11.Please disclose what ECG stands for in this section.
12.Please expand to provide the basis for the statement following Figure 5 that a 30%
reversal in peak mAIMS scores is acknowledged as being clinically meaningful.
Safety and Tolerability Data, page 67
13.Please revise to make clear that all treatment-emergent serious adverse events have been
disclosed, and expand your disclosure as necessary.
UDysRS, the Primary Endpoint, page 70
14.We note your disclosure that the "the objective assessment by the rater included in the
UDysRS, should favor dipraglurant in study 301."  Please revise this statement to remove
any implication that you will achieve favorable results.
mGlu2 NAM for the treatment of mild cognitive impairment, page 75
15.We note your statement that you believe you are developing "the most advanced subtype
selective mGlu2 NAM."  Please delete this statement given the early stage of development
of this candidate.
Material agreements, page 77
16.For both material agreements discussed in this section, please disclose the duration of the
agreement, the royalty term and the termination provisions.

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 October 23, 2019 Page 4
 FirstName LastNameTim Dyer
Addex Therapeutics Ltd.
October 23, 2019
Page 4
Intellectual Property
Patents and Proprietary Rights, page 78
17.For each patent family, please disclose the applicable jurisdictions for your granted
patents to the extent that you have not already done so.
Principal Holders, page 101
18.Please revise your disclosure to identify the natural person or persons who have voting
and investment control of the shares held by Addex Pharma SA, Growth Equity
Opportunities Fund IV, LLC, New Leaf Biopharma Opportunities I, L.P. and CS (CH)
Small Cap Switzerland Equity Fund.
Financial Statements
Notes to Financial Statements
13. Revenue from contract with customer
License & research agreement with Indivior PLC, page F-30
19.You concluded that "The contract contained two distinct performance obligations, the
provision of a license to intellectual property (IP) and the provision of research services to
discover novel GABAB PAM compounds" and the full upfront payment of CHF 5 million
was allocated to the right-of-use license of intellectual property based on the stand-alone
selling price and was recorded when the right to use the IP was transferred in January
2018.  Please explain to us how you considered that because it appears Indivior cannot
benefit from the license without the research services, you did not conclude that the
license and the research services are not capable of being distinct, and the promises should
be accounted for as a combined performance obligation. Our understanding is that
Indivior has not selected drug candidates yet.
General
20.Please provide us proofs of all graphics, visual, or photographic information you will
provide in the printed prospectus prior to its use, for example in a preliminary prospectus.
Please note that we may have comments regarding this material.
            You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at 202-551-3614
if you have questions regarding comments on the financial statements and related
matters.  Please contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-
3625 with any other questions.

 FirstName LastNameTim Dyer
 Comapany NameAddex Therapeutics Ltd.
 October 23, 2019 Page 5
 FirstName LastName
Tim Dyer
Addex Therapeutics Ltd.
October 23, 2019
Page 5
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua A. Kaufman, Esq.