March 25, 2020

Christopher Martin
Chief Executive Officer
ADC Therapeutics SA
Biop le, Route de la Corniche 3B
1066 Epalinges
Switzeland

       Re: ADC Therapeutics SA
           Draft Registration Statement on Form F-1
           Submitted March 2, 2020
           CIK No. 0001771910

Dear Mr. Martin:

       We have reviewed your draft registration statement 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 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 comments apply 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 these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Significant Judgments and Estimates
Employee Benefits
Share-Based Compensation Expense, page 95

1.     Once you have an estimated offering price range, please explain to us
the reasons for any
       differences between recent valuations of your common shares leading up
to the planned
       offering and the midpoint of your estimated offering price range. This
information will
       help facilitate our review of your accounting for equity issuances,
including stock
       compensation.
 Christopher Martin
ADC Therapeutics SA
March 25, 2020
Page 2

        You may contact Franklin Wyman at (202) 551-3660 or Lisa Vanjoske at
(202) 551-
3614 if you have questions regarding comments on the financial statements and
related matters.
Please contact Tonya K. Aldave at (202) 551-3601 or Dietrich King at (202)
551-8071 with any
other questions.



                                                           Sincerely,
FirstName LastNameChristopher Martin
                                                           Division of
Corporation Finance
Comapany NameADC Therapeutics SA
                                                           Office of Life
Sciences
March 25, 2020 Page 2
cc:       Yasin Keshvargar, Esq.
FirstName LastName