December 18, 2018

Dan Peisert
Senior Vice President and Chief Financial Officer
Assertio Therapeutics, Inc
100 South Saunders Road, Suite 300
Lake Forest, IL 60045

       Re: Assertio Therapeutics, Inc
           Form 10-K for the fiscal year ended December 31, 2017
           Filed March 1, 2018
           Form 10-Q for the quarterly period ended September 30, 2018
           Filed November 9, 2018
           File No. 001-13111

Dear Mr. Peisert:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Form 10-Q for the quarterly period ended September 30, 2018

Financial Statements
Note 4. Revenue
Commercialization Agreement with Collegium, page 17

1.    Regarding the January 2018 Collegium agreement, for which you determined
the total
      transaction price to be $553 million, please provide us your analysis of
the accounting for
      the agreement which explains why you did not recognize any portion of the
consideration
      for the license upon transfer of the license at inception of the
agreement. Address:
        If you concluded the license was distinct from the other obligations
and why or why
          not,
        If you concluded the license was a right to use license or a right to
access license and
 Dan Peisert
Assertio Therapeutics, Inc
December 18, 2018
Page 2
             why,
             The standalone selling prices determined for each performance
obligation and how
             you determined such,
             Why you did not recognize the guaranteed minimum royalty payments
as fixed
             consideration upon transfer of the license at inception of the
agreement, and
             Why you combined the license with the services to arrange for
supplies.

       In closing, 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.

       You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at
202-551-3614
with any questions.



FirstName LastNameDan Peisert                               Sincerely,
Comapany NameAssertio Therapeutics, Inc
                                                            Division of
Corporation Finance
December 18, 2018 Page 2                                    Office of
Healthcare & Insurance
FirstName LastName