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                             April 13, 2021

       Scott Burrows
       Chief Financial Officer
       Arcutis Biotherapeutics, Inc.
       3027 Townsgate Road Suite 300
       Westlake Village , California

                                                        Re: Arcutis
Biotherapeutics, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 16,
2021
                                                            File No. 001- 39186

       Dear Mr. Burrows:

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

              Please respond to the 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 the comment, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Research and Development Expenses, page 91

   1.                                                   You present a table of
direct and indirect costs on page 91 and disclose on page 89 that
                                                        you allocate direct
external costs to your product candidates. Considering that your
                                                        product candidates are
now in more advanced late stages of clinical trials, please
                                                        provide disaggregated
disclosure for external costs by product candidate or
                                                        indication incurred for
each period or tell us why additional disclosure cannot be
                                                        provided.
              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.
 Scott Burrows
Arcutis Biotherapeutics, Inc.
April 13, 2021
Page 2

       You may contact Li Xiao at (202) 551-4391 or Mary Mast at (202) 551-3613
with any
questions.



FirstName LastNameScott Burrows                         Sincerely,
Comapany NameArcutis Biotherapeutics, Inc.
                                                        Division of Corporation
Finance
April 13, 2021 Page 2                                   Office of Life Sciences
FirstName LastName