November 1, 2018

Michael F. Kanan
Senior Vice President and Chief Financial Officer
Avadel Pharmaceuticals plc
Block 10-1
Blanchardstown Corporate Park
Ballycoolin
Dublin 15
Ireland

       Re: Avadel Pharmaceuticals plc
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 16, 2018 and Amended April 30, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 7, 2018
           File No. 001-37977

Dear Mr. Kanan:

        We have reviewed your October 4, 2018 response to our comment letter
and have the
following comment. In our comment, we ask you to provide us with information so
we may
better understand your disclosure.

       Please respond to this comment within 10 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 this comment, we may have additional
comments. Our
reference to a prior comment is to the comment in our September 20, 2018
letter.

Form 10-Q for the Quarterly Period Ended June 30, 2018

Notes to the Unaudited Condensed Consolidated Financial Statements
Note 3: Revenue Recognition
Periods commencing January 1, 2018
Reserves to reduce Gross Revenues to Net Revenues, page 11
 Michael F. Kanan
Avadel Pharmaceuticals plc
November 1, 2018
Page 2
1.       We acknowledge your response to our prior comment. Please explain to
us why
         adjustments to prior year estimates of gross-to-net variable
consideration in the aggregate
         of up to 3% of total revenues are not material to your financial
statements taken as a
         whole. In this regard, 3% of your total revenues for the first half of
2018 equating to
         approximately $1.9 million appears that it could at least be
quantitatively material to
         operating loss and pre-tax loss for the first half of 2018 and to your
customer allowances
         liability at December 31, 2017. In addition, prior period adjustments
of that magnitude
         could significantly impact trends and explanation thereof could be
meaningful disclosure
         for investors.
       You may contact Mark Brunhofer at (202) 551-3638 or Mary Mast at (202)
551-3613
with any questions.



FirstName LastNameMichael F. Kanan                             Sincerely,
Comapany NameAvadel Pharmaceuticals plc
                                                               Division of
Corporation Finance
November 1, 2018 Page 2                                        Office of
Healthcare & Insurance
FirstName LastName