November 10, 2021




Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549


Re: Journey Medical Corporation
  Registration Statement on Form S-1
  File No. No. 333-260436


Acceleration Request

  Requested Date: November 10, 2021
  Requested Time: 4:00 p.m. Eastern Time (US)


Ladies and Gentlemen:


In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representative of the underwriters, hereby join in the request of Journey Medical Corporation that the effective date of the Registration Statement be accelerated so that it will be declared effective at 4:00 p.m., Eastern Time (US), on November 10, 2021, or at such later time as the Company or its outside counsel, Alston & Bird LLP, may request via a telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.


Pursuant to Rule 460 under the Act, we wish to advise you that we have distributed approximately 495 copies of the Preliminary Prospectus dated November 8, 2021 through the date hereof, to underwriters, dealers, institutions and others.


The undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.


  Very truly yours,
  Acting on behalf of itself and the several Underwriters
  By: /s/ Jonathan C. Rich
  Name: Jonathan C. Rich
  Title: Senior Managing Director – Head of Investment Banking Solutions