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June 20, 2023

John Bencich
Chief Executive Officer
ACHIEVE LIFE SCIENCES, INC.
22722 29th Drive SE, Suite 100
Bothell, WA 98021

Re: ACHIEVE LIFE
SCIENCES, INC.
Registration
Statement on Form S-3
Filed June 14, 2023
File No. 333-272641

Dear John 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 Arzhang
Navai at 202-551-4676 with any questions.




Sincerely,


Division of Corporation Finance

Office of Life Sciences
cc: Chelsea Anderson