[JENKENS & GILCHRIST LETTERHEAD] January 24, 2005 VIA TELECOPIER AND FIRST CLASS MAIL (202) 942-9585 David Ritenour, Esq. Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street NW Washington, D.C. 20549 RE: PHOTOMEDEX, INC. REGISTRATION STATEMENT ON FORM S-3 FILE NO. 333-120921 Dear Mr. Ritenour: Per our earlier conversations, PhotoMedex, Inc. is hereby requesting that the effectiveness of the Registration Statement on Form S-3 (File No. 333-120921) be accelerated to Monday, January 24, 2005 at 5:00 p.m.. (Eastern Time). We enclose copies of the Company's request for acceleration and the additional acknowledgement letter (referenced in the Staff's December 21, 2004 correspondence), each dated as of January 24, 2005. If you have any further questions, please call me at my office. Very truly yours, /s/ Kenneth M. H. Hoff Kenneth M.H. Hoff for JENKENS & GILCHRIST, LLP ENCLOSURE cc: DENNIS M. MCGRATH JEFFREY P. BERG, ESQ.