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                               November 8, 2023

       Timothy E. Sullivan
       Chief Financial Officer and Treasurer
       Apellis Pharmaceuticals, Inc.
       100 Fifth Avenue
       Waltham, MA 02451

                                                        Re: Apellis
Pharmaceuticals, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 21,
2023
                                                            Form 10-Q for the
period ended September 30, 2023
                                                            Filed November 1,
2023
                                                            File No. 001-38276

       Dear Timothy E. Sullivan:

                                                        We have reviewed your
filings and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Financial Operations Overview
       Research and Development Expenses, page 33

   1.                                                   You disclose that you
have not provided program costs since inception because
                                                        historically you have
not tracked or recorded your research and development expenses on
                                                        a program-by-program
basis. Please tell us whether you currently track any of your
                                                        research and
development costs by program or indication. If so, provide disaggregated
                                                        disclosure for each
significant clinical trial for each period presented. If not, revise your
                                                        disclosure to state the
fact that you do not currently track clinical trial costs separately.
       Form 10-Q for the period ended September 30, 2023

       Results of Operations for the Nine Months Ended September 30, 2023 and
2022
 Timothy E. Sullivan
Apellis Pharmaceuticals, Inc.
November 8, 2023
Page 2
Cost of Sales, page 33

2.       You indicate that you have pre-FDA approved inventory on hand and that
you expect this
         to continue to impact your cost of sales. Please quantify the
remaining pre-FDA
         approved inventory as of September 30, 2023 and how long you expect
this to continue to
         impact cost of sales. If material, please provide this disclosure in
future filings, similar to
         your disclosure in the Notes to the Financial Statements in your Form
10-K for the period
         ended December 31, 2022 on page 127.
        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 Sasha Parikh at 202-551-3627 or Vanessa Robertson at
202-551-3649 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameTimothy E. Sullivan                            Sincerely,
Comapany NameApellis Pharmaceuticals, Inc.
                                                                 Division of
Corporation Finance
November 8, 2023 Page 2                                          Office of Life
Sciences
FirstName LastName