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                          May 2, 2024

       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 April 26,
2024
                                                            File No. 333-278961

       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 Lauren
Hamill at 303-844-1008 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Chelsea Anderson