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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