0001104659-20-020153.txt : 20200317 0001104659-20-020153.hdr.sgml : 20200317 20200213160340 ACCESSION NUMBER: 0001104659-20-020153 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200213 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AVADEL PHARMACEUTICALS PLC CENTRAL INDEX KEY: 0001012477 STANDARD INDUSTRIAL CLASSIFICATION: PHARMACEUTICAL PREPARATIONS [2834] IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: BLOCK 10-1 BLANCHARDSTOWN CORPORATE PARK STREET 2: BALLYCOOLIN CITY: DUBLIN STATE: L2 ZIP: 15 BUSINESS PHONE: 636-449-1830 MAIL ADDRESS: STREET 1: 16640 CHESTERFIELD GROVE ROAD STREET 2: SUITE 200 CITY: CHESTERFIELD STATE: MO ZIP: 63005 FORMER COMPANY: FORMER CONFORMED NAME: FLAMEL TECHNOLOGIES SA DATE OF NAME CHANGE: 19960422 CORRESP 1 filename1.htm

Avadel Pharmaceuticals plc

10 Earlsfort Terrace

Dublin 2, Ireland

D02 T380

February 13, 2020

Via EDGAR Transmission

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Avadel Pharmaceuticals plc: Registration Statement on Form S-3 filed February 5, 2020 (File No. 333-236258)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Avadel Pharmaceuticals plc (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to February 17 , 2020, at 4:01 pm 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.

If you have any questions regarding this request, please contact Robert E. Puopolo of Goodwin Procter LLP at (617) 570-1393.

	Sincerely,
	Avadel Pharmaceuticals plc

	/s/ Gregory J. Divis

	Gregory J. Divis
	Chief Executive Officer and Principal Executive Officer

cc:	Thomas McHugh, Avadel Pharmaceuticals plc
	Phillandas Thompson, Avadel Pharmaceuticals plc
	Robert E. Puopolo, Esq., Goodwin Procter LLP