November 8, 2018

Bruce Cozadd
Chairman and Chief Executive Officer and Director
Jazz Pharmaceuticals plc
Fifth Floor, Waterloo Exchange
Waterloo Road, Dublin 4, Ireland

       Re: Jazz Pharmaceuticals plc
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 6, 2018
           File No. 001-33500

Dear Mr. Cozadd:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we ask you to
provide us with
information so we may better understand your disclosure.

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

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

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

Notes to Condensed Consolidate Financial Statements
2. Disposition, page 11

1.    Please provide us an analysis with reference to authoritative literature
supporting your
      determination of a $.5 million loss on sale to TerSera of the assets
related to Prialt. In
      particular, address how you considered the $30 million of payments
subject to certain
      conditions that may be received in the future and the literature upon
which you relied.
 Bruce Cozadd
Jazz Pharmaceuticals plc
November 8, 2018
Page 2



       In closing, 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.

       You may contact Keira Nakada at 202-551-3659 or Jim Rosenberg at
202-551-3679 with
any questions.



FirstName LastNameBruce Cozadd                            Sincerely,
Comapany NameJazz Pharmaceuticals plc
                                                          Division of
Corporation Finance
November 8, 2018 Page 2                                   Office of Healthcare
& Insurance
FirstName LastName