November 8, 2018

L. Daniel Browne
President and Chief Executive Officer
Revance Therapeutics, Inc.
7555 Gateway Boulevard
Newark, California 94560

       Re: Revance Therapeutics, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 2, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 3, 2018
           File No. 001-36297

Dear Mr. Browne:

       We have reviewed your October 5, 2018 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to our prior comment is to
the comment in
our September 12, 2018 letter.

Form 10-Q for the Quarterly Period Ended June 30, 2018

Notes to Condensed Consolidated Financial Statements
3. Collaboration and License Revenue , page 12

1.    In your response to the first bullet of our prior comment, you
acknowledge that the
      material right from Mylan's Continuation Option is a separate performance
obligation and
      that you utilized the practical alternative set forth in ASC 606-10-55-45
to
      determine the amount of the transaction price to allocate to this
performance obligation.
      Please quantify the portion of the transaction price allocated to the
Mylan Continuation
 L. Daniel Browne
Revance Therapeutics, Inc.
November 8, 2018
Page 2
      Option and clarify the timing of revenue recognition (e.g., over time or
when the option is
      exercised or terminated).
2.    In your response to the second bullet of our prior comment, you assert
that the inclusion of
      cost-sharing payments and certain milestones in your transaction price at
no point results
      in a scenario where the revenue recognized exceeds the cash received
to-date. You further
      assert that it is not probable that a significant reversal of cumulative
revenue recognized
      would occur, regardless of whether Mylan exercises its continuation
option and whether
      the collaboration progresses as expected. Please provide us with a
quantitative analysis
      that supports these assertions.
3.    In your response to the third bullet of our prior comment you describe
your process for
      estimating the $16 million of cost-sharing payments included in your
transaction
      price. Please address the following:

          Your response indicates that a new development plan and budget for
completing
          development and commercialization of the product will not occur until
the FDA
          confirms whether the biosimilar pathway for BOTOX is feasible. Please
explain how
          you were able to estimate the scope of your development activities
and your total
          development costs when the Initial Phase has not been completed, the
FDA has not
          confirmed feasibility and the Continuation Option has not yet been
exercised by
          Mylan.
          Explain how you were able to estimate the expected costs to be
incurred by Mylan for
          purposes of determining the net cost sharing payments included in
your transaction
          price.
       You may contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.



                                                            Sincerely,
FirstName LastNameL. Daniel Browne
                                                            Division of
Corporation Finance
Comapany NameRevance Therapeutics, Inc.
                                                            Office of
Healthcare & Insurance
November 8, 2018 Page 2
cc:       Cyril Allouche
FirstName LastName