Mail Stop 3561
                                                            June 29, 2018

Via E-mail
Brian Markison
Chief Executive Officer
Osmotica Pharmaceuticals plc
400 Crossing Boulevard
Bridgewater, NJ 08807

       Re:     Osmotica Pharmaceuticals plc
               Amendment No. 1 to
               Draft Registration Statement on Form S-1
               Submitted June 20, 2018
               CIK No. 0001739426

Dear Mr. Markison:

       We have reviewed your amended draft registration statement and have the
comment. In our comment, we may ask you to provide us with information so we
may better
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

        After reviewing the information you provide in response to this comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
June 5, 2018 letter.

Capitalization, page 70

1.     We note your revised disclosures do not appear to fully address the
issue noted in
       Comment 5. For example, although you allude to the issuance of ordinary
       described under "The Reorganization," your disclosure does not provide
further details
       on share amounts. Upon finalization of reorganization and offering
transactions, please
       confirm that you will include detailed disclosures regarding the
adjustments made in
       arriving at the pro forma and pro forma as adjusted amounts
 Brian Markison
Osmotica Pharmaceuticals plc
June 29, 2018
Page 2

       You may contact Raj Rajan at (202) 551-3388 or Craig Arakawa at (202)
551-3650 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Michael Killoy at (202) 551-7576 or David Link at (202) 551-3356 with
any other


                                                          /s/ David Link for

                                                          John Reynolds
                                                          Assistant Director
                                                          Office of Beverages,
                                                          and Mining

cc:    Craig E. Marcus, Esq.
       Ropes & Gray LLP