February 7, 2019

John Bencich
Chief Financial Officer
ACHIEVE LIFE SCIENCES, INC.
1001 W. Broadway, Suite 400
Vancouver, British Columbia, V6H 4B1

       Re: ACHIEVE LIFE SCIENCES, INC.
           Registration Statement on Form S-3
           Filed December 26, 2018
           File No. 333-229019

Dear Mr. Bencich:

       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 Todd Schiffman at 202-551-3491 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Healthcare & Insurance