April 4, 2020

Corey Fishman
President and Chief Executive Officer
Iterum Therapeutics plc
200 South Wacker Drive, Suite 2550
Chicago, IL 60606

       Re: Iterum Therapeutics plc
           Registration Statement on Form S-1
           Filed March 20, 2020
           File No. 333-237326

Dear Mr. Fishman:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1 filed March 20, 2020

Cover Page

1.     Please revise the coverpage presentation concerning the Exchangeable
Notes to identify
       the exchange rate and clarify whether it is a fixed or floating rate.
With respect to the
       Royalty-Linked Notes, revise the coverpage to explain and highlight
briefly what these
       notes are and their material features. For instance, it should be clear
what royalties and
       drug candidates are at issue, the absence of principal and interest
payments, and the time
       horizon for the security. Also, highlight the complexities of the
Royalty-Linked Notes
       and the tax risks applicable to U.S. holders. Also, revise the coverpage
to indicate that
       both instruments are subject to redemption.
2.     With reference to your fee table, please revise the coverpage to
disclose the number of
       ordinary shares that you are registering.
 Corey Fishman
Iterum Therapeutics plc
April 4, 2020
Page 2
3.       Please revise the third paragraph to indicate whether there is any
limitation on your ability
         to extend the offering.
The Royalty-Linked Notes, page 14

4.       Please revise to:

              Disclose the number of Royalty-Linked Notes outstanding before
and after the
              offering, and discuss any risks associated with potential future
issuances.
              Clarify what 50 Notes entitles the holder to receive. For
instance, please add a table
              to demonstrate the range of payouts that would be owed to
investors under various
              scenarios relating to asset performance and, as applicable, the
number of Royalty-
              Linked Notes outstanding.
              Discuss the development status of the drug product candidates
(including
              development plans and timelines) relevant to the performance of
these Royalty-
              Linked Notes.
Exhibits

5.       Please explain to us why counsel includes the final paragraph on page
3 of the Exhibit 5.1
         legal opinion concerning the Royalty-Linked Notes.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Jeffrey Gabor at (202) 551-2544 or Joe McCann at (202)
551-6262 with
any questions.



FirstName LastNameCorey Fishman                                Sincerely,
Comapany NameIterum Therapeutics plc
                                                               Division of
Corporation Finance
April 4, 2020 Page 2                                           Office of Life
Sciences
FirstName LastName