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                             November 1, 2021

       Claude Maraoui
       Chief Executive Officer, President and Director
       Journey Medical Corporation
       9237 E Via de Ventura Blvd., Suite 105
       Scottsdale, AZ 85258

                                                        Re: Journey Medical
Corporation
                                                            Registration
Statement on Form S-1
                                                            Filed October 22,
2021
                                                            File No. 333-260436

       Dear Mr. Maraoui:

              We have reviewed your 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 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

       Use of Non-GAAP Measures, page 63

   1.                                                   We note your COVID-19
sales force savings adjustment is due to the fact that you did not
                                                        incur salary expense
related to your field sales forces. As such, it appears this Non-GAAP
                                                        adjustment is for an
amount that is not in your historical GAAP financial statements and
                                                        was not part of your
operating results for that period, which would be prohibited by Item
                                                        10(e)(2) of Regulation
S-K. Please revise your presentation accordingly.
       Product Licensing Agreements and Acquisitions, page 76

   2.                                                   With respect to your
Accutane and Exelderm Agreements, please revise the references to
                                                        "low-double digits" to
provide a more defined range of royalties that does not exceed ten
                                                        percentage points
(e.g., teens or low teens).
 Claude Maraoui
Journey Medical Corporation
November 1, 2021
Page 2

        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.

       You may contact Michael Fay at (202) 551-3812 or Kevin Vaughn at (202)
551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Gary Guttenberg at (202) 551-6477 or Jeffrey Gabor at (202) 551-2544
with any other
questions.



                                                           Sincerely,
FirstName LastNameClaude Maraoui
                                                           Division of
Corporation Finance
Comapany NameJourney Medical Corporation
                                                           Office of Life
Sciences
November 1, 2021 Page 2
cc:       Mark F. McElreath, Esq.
FirstName LastName