United States securities and exchange commission logo 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