TEXT-EXTRACT 2 filename2.txt September 13, 2019 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, 2018 Filed March 15, 2019 File No. 001-37977 Dear Mr. Kanan: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance