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CORRESP
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      responselettermainbody

              Cane
                Clark LLP

              3273
                E. Warm Springs

              Las
                Vegas, NV 89120

              Kyleen
                E. Cane*

              Bryan
                R. Clark^

              Chad
                Wiener+

              Scott
                P. Doney~

              Telephone:
                702-312-6255

              Facsimile:
                702-944-7100

              Email:
                kcane@caneclark.com

    September
      16, 2005

    UNITED
      STATES SECURITIES AND EXCHANGE

    COMMISSION-Division
      of Corporation Finance

    Mail
      Stop
      7010

    100
      F.
      Street NE

    Washington,
      D.C. 20549-7010

    ATTENTION:
      Meagan Caldwell

    Re: Davi
      Skin, Inc.

    Form
      10-KSB for the fiscal year ended December 31, 2004

    Form-10QSB
      for the period ended March 31, 2005

    File
      No: 0-32843

    ________________________________________________________________________________

    We
      write
      on behalf of Davi Skin, Inc. (the “Company”) in response to Staff's letter of
      August 18, 2005 by Rufus Decker Accounting Branch Chief of the United States
      Securities and Exchange Commission (the “Commission”) regarding the
      above-referenced Form 10KSB and Form 10QSB (the “Comment Letter”). On behalf of
      the Company, we have attached to this response letter as an exhibit proposed
      Amended Financials to the Form 10KSB (the “First Amended 10-KSB") and proposed
      Amended Financials to the Form 10QSB (the “First amended 10QSB”) to represent
      the changes that will be made and filed when all comments have been satisfied
      in
      your review process. The Company has also committed to similarly amend its
      most
      recent Form 10QSB for the period ended June 30, 2005 to conform to these
      changes.

    The
      factual information provided herein relating to the Company has been made
      available to us by the Company. Paragraph numbering used for each response
      corresponds to the numbering used in the Comment Letter.

    Form
      10-KSB for the year ended December 31, 2004

    Comment
      applicable to your overall filing

              1.

                Where
                  a comment below requests additional disclosures or other revisions
                  to be
                  made, please show us in your supplemental response what the revisions
                  will
                  look like. With the exception of the comments below that specifically
                  request amendment, all other revisions may be included in your
                  future
                  filings.

    In
      response to this comment, the Company acknowledges this request regarding
      revisions.

    Item
      1. Description of Business

            2.

              Please
                expand your disclosure to include information regarding the sources
                and
                availability of your raw materials. In addition, please include a
                discussion of any material agreements you have entered into with
                suppliers. Refer to item 101(b)(5) of Regulation
                S-B.

    In
      response to this comment, the Company will include information regarding the
      sources and availability of raw materials and a discussion of material
      agreements in future filings. This information shall include the
      following:

    1.
      A
      discussion of certain agreement with laboratories regarding the testing and
      manufacture of the products under development. In this regard we note that
      the
      company currently has agreements with two laboratories for testing and four
      products are in various stages of testing but generally close to completion.
      Five products are just beginning the testing process with the second laboratory.
      As laboratories that can test and manufacture the anticipated products that
      are
      readily available, the company does not determine these to be material
      agreements that need to be disclosed.

    2.
      A
      discussion of arrangements made with certain Wineries regarding the delivery
      and
      availability of raw materials. The Company will further provide information
      on
      the anticipated raw materials, disclosing that they are readily available from
      various sources at reasonable costs.

            3.

              you
                disclosed on page 11 that you have a contract with a formulator to
                create
                a series of skin crème products. Please expand your disclosure to include
                a discussion regarding the significant terms of the
                contract.

    In
      response to this comment, the Company will expand on its disclosure regarding
      the significant terms of the formulation contract in future filings. Currently,
      this is simply to create various formulations and to test them for a fee.

    Item
      5. Market for Common Equity and Related Stockholder Matters, page
      9

            4.

              your
                disclosure does not appear to have given retroactive effect for the
                500
                for 1 reverse stock split, which occurred in June 2004. Please expand
                your
                disclosure to include a discussion regarding the significant terms
                of the
                contract.

    In
      response to this comment, the Company made various requested changes to the
      financials to correct any deficient disclosures. Please note that the reverse
      stock split happened before the merger. Disclosures relate to the new entity,
      and not the prior one. Shares issued as part of the merger reflect the effect
      of
      the reverse stock split.

        2

    Report
      of Independent Registered Public Accounting Firm, page F-1

            5.

              The
                independent auditor’s report included in your filing is not signed by your
                auditor. Please obtain from your auditor a signed audit report and
                file an
                amended Form 10-KSB to include this. In doing so, please ensure you
                update
                your signature page and include updated certifications in your
                amendment.

    In
      response to this comment, the Company obtained a signed audit report from the
      auditor. The Company’s amended Form 10KSB reflects the proper signature pages
      and certifications. A copy of the signed audit report is attached in the
      proposed amended financials that are attached.

            6.

              your
                independent accountant, smith & Company, is duly registered and in
                good standing to practice in Utah. However, Smith & Company does not
                appear to be currently licensed in Nevada where you are incorporated.
                We
                remind you, that it is your responsibility ot provide financial statements
                audited by an auditor who meets the requirements of Rule 2-01(a)
                of
                Regulation S-X. Tell us how you have met the requirments of Rule
                2-01(a)
                of S-X. Please also tell us what consideration you gave to Nevada
                state
                laws governing audits of Nevada companies performed by accountants
                from
                other states.

    In
      response to this comment, please be advised that Nevada law does not require
      licensing when no fieldwork is conducted within the boundaries of the State.
      Smith & Company is duly registered and in good standing in California where
      the Company’s principal office and operations are located.

    Financial
      Statements

    Statements
      of Operations, page F-3

            7.

              your
                disclosure on page F-7 indicates that the effect of common stock
                equivalents in the current year would have had an anti-dilutive effect
                on
                EPS in the current year. However, it appears as though these common
                stock
                equivalents were included it the diluted weighted average common
                shares
                outstanding used in the calculation of dilution loss per common share
                included in your statements of operations. If the common stock equivalents
                that had an anti dilutive effect on EPS were in fact included in
                your
                diluted loss per common share calculation, please revise your calculation
                and file an amended Form 10-KSB.

    In
      response to this comment, please note that the disclosure properly states that
      the effect of common stock equivalents was anti-dilutive. Corrections have
      been
      made to the face of the statement of operations to reflect this.

        3

    Statement
      of Stockholders’ Equity, Page F-4

            8.

              You
                have reflected the deficit in stockholders’ equity which resulted from the
                operations of MW Medical as an adjustment to additional paid-in capital,
                rather than in accumulated deficit during development stage. Please
                amend
                your filing on Form 10-KSB for the year ended December 31, 2004 and
                your
                subsequent Forms 10-QSB to reflect this
                change.

    In
      response to this comment, the Company made the
      requested changes.

    Statements
      of Cash Flows, page F-5

            9.

              You
                have included cash received from notes payable in operating activities,
                rather than in financing activities. Please amend your filing on
                Form
                10-KSB and your subsequent Forms 10-QSB to reflect this change. Refer
                to
                paragraphs 18 to 20 of SFAS 95.

    In
      response to this comment, the Company made the requested changes.

    1.
      Description of the business, history and summary of significant policies, page
      F-6

    Earnings
      (loss) per share, page F-7

            10.

              Please
                expand your disclosure to include a reconciliation regarding the
                computation of the numerators and the denominators of the basic and
                diluted per-share net loss information. Refer to paragraph 40(a)
                of SFAS
                128.

    In
      response to this comment, please note that because the Company experienced
      a net
      loss, any common stock equivalents would be anti-dilutive. No reconciliation
      is
      needed because the amended financial disclosures have eliminated any reference
      to diluted earnings per share.

            11.

              You
                disclose that common stock equivalents were excluded from your calculation
                of diluted loss per share. Please expand your disclosure to include
                separately by type of security the number of securities that were
                not
                included in the calculation of diluted EPS because they would have
                had and
                antidilutive effect. Refer to paragraph 40 (C) of SFAS
                128.

    In
      response to this comment, the Company made the requested changes taking into
      account all other corrections made concerning earnings per share.

        4

    Stock
      based compensation, page F-8

            12.

              You
                disclosed on page 10 that you issued options to purchase 435,000
                shares of
                your common stock to five employees and consultants during the third
                quarter. However, you state in this footnote that for the period
                from
                March 21, 2004 (date of inception) through December 31, 2004 you
                did not
                grant stock options or warrants to employees. Please make the necessary
                adjustments to your disclosure to clarify this apparent
                inconsistency.

    In
      response to this comment, please note that stock options were issued to five
      outside consultants and no employees. Corrections have been made to more clearly
      state this. All other disclosure requirements have been corrected and included,
      as applicable. Page 10 of the Amended 10KSB will read as follows in the last
      two
      sentences: “We also issued to five consultants options to purchase 435,000
      shares of our common stock at prices ranging from $0.50 to $1.00. These shares
      were issued pursuant to our incentive stock option plan.”

            13.

              You
                disclosed on pages 10 and F-10 that you issued 435,000 stock options
                to
                consultants and five of your employees. Your disclosure on page F-10
                indicates that 415,000 of these options were issued with an exercise
                price
                of $0.50 and the remaining 20,000 options were issued with an execise
                price of $1.00. Please expand your disclosure to include the
                following:

            ·

              the
                grant date,

            ·

              the
                number of shares issued to
                employees,

            ·

              the
                number of shares issued to
                non-employees,

            ·

              the
                vesting period for each option grant,
                and

            ·

              the
                amounts, if any recorded as expense and the line items affected in
                your
                financial statements

    Please
      tell us the assumptions you used in determining the expense recorded, and those
      used in determining the exercise price of each option grant. Please also include
      in your response the consideration you gave to the 300,000 shares of common
      stock, also issued during the third quarter, in determining the stock option
      issuance price for the grants issued above.

    In
      response to this comment, please see the above response. In addition, the
      Company expanded the disclosure to include the requested information.

            14.

              Please
                expand your disclosure to include information relating to your stock
                options required by paragraphs 45 through 48 of SFAS 123 (R) as amended
                by
                SFAS 148.

    In
      response to this comment, please note that no stock options were issued to
      employees.

        5

    6. Capital Stock Transactions, page F-9

            15.

              you
                disclosed that you issued 300,000 shares of common stock to three
                individuals based on their consulting service contracts and that
                the value
                of these services were $2,634,375. However, based on your statement
                of
                stockholders’ equity, it appears as though the common stock was issued for
                $3,675,915. Please exand your disclosure to include additional information
                regarding the apparent $1,041,540
                discrepancy.

    In
      response to this comment, the Company made the requested changes to reconcile
      the discrepancy.

      Form
        10-QSB for the period ended March 31, 2005

    Comments
      applicable to your overall filing