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CORRESP
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              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

    December
      6, 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:      Form
      10-KSB for the Fiscal Year Ended December 31, 2004

     Form
      10-QSB for the Fiscal Quarter Ended June 30, 2005

     Form
      10-QSB for the Fiscal Quarter 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
      October 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 Forms 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
      you review process. The Company has also committed to similarly amend its most
      recent Form 10QSB for the period ended September 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 Fiscal 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 exceptions of the comments below that specifically
                request an amendment, all other revisions may be included in your
                future
                filings.

    *Licensed
      Nevada, California, Washington and Hawaii Bars;

    ^
      Nevada,
      Colorado and District of Columbia Bars

    +
      Illinois, and Wisconsin State Bars ~Nevada

    In
      response to this comment, the Company acknowledges Staff’s request regarding the
      presentation of the information.

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

    2.     We
      read your
      response to our comment 7 from our letter dated September 19, 2005. The
      explanatory paragraph included in your auditors' report does not reference
      the   restatement related to the classification of cash received from
      notes payable in your statements of cash flows. As previously requested, please
      obtain an updated opinion from your auditors that reference all
      restatements.

    In
      response to this comment, the Company has obtained and provided an updated
      auditors’ report with the referenced restatement.

    Financial
      Statements

    Statement
      of Stockholders' Equity, page
      F-4

              3.

              We
                reviewed your proposed revised statement of stockholders' equity.
                The
                activity and related ending balances presented in your proposed statement
                of stockholders' equity do not equal the amounts presented in your
                balance
                sheet. Please revise accordingly. In addition, it appears as though
                you
                have changed the valuation of your prepaid consulting contract from
                approximately $1.8 million to $0.1 million. Please tell us the facts
                and
                circumstances which support this change in
                valuation.

    In
      response to this comment, the Company has corrected the statement of
      stockholders’ equity to equal the amounts presented in the balance sheet. In
      addition, as noted in our response to comment 12 in our letter dated October
      4,
      2005, the Company reviewed its valuation and the timing of the stock grant
      and
      in conjunction with its auditors determined that the valuation of the stock
      grants for the consulting services should have actually been 50 cents per share
      (rather than $3.00 or greater) based on the stock sales made at the time, the
      almost complete lack of trading volume in the market at the time the consulting
      agreements were negotiated, the price of option grants to these same consultants
      and the restrictive nature of the stock granted. Thus, the Company revised
      its
      entries throughout, including the balance sheet as well as Note 6 to reflect
      this valuation consistently. The Company has also included a more detailed
      discussion of the respective issuance prices of each of the transactions
      discussed in its footnotes.

              4.

              Your
                response to our comment 12 from our letter dated August 18, 2005
                and your
                revised disclosure in note 7 to your financial statements indicates
                that
                you issued 435,000 options to non-employee outside consultants. Please
                tell us how you have reflected the fair value, which you deemed to
                be
                approximately $1.1 million in your financial
                statements.

        2

    In
      response to this comment, the Company advises that the fair value of the options
      was recorded as follows:

    DR Legal
      Fees
      Expense
751,948

    DR Consulting
      Fees Expense    329,144

    CR Additional
      Paid in
      Capital
1,081,092

    Notes
      to Financial
      Statements

              5.

              We
                reviewed your proposed revision to your statements of cash flows
                regarding
                cash received from notes payable. Your proposed notes to your financial
                statements regarding your restatements do not include a discussion
                regarding this restatement. Please revise Note 8 to your financial
                statements to present information for all restatements. Please ensure
                that
                each restatement is separately discussed in your disclosure. Similarly,
                please revise your Forms 10-QSB to include this information as
                well.

    In
      response to this comment, the Company has added the requested discussion
      regarding the restatements separately in the 10K and 10Qs.

    Description
      of Business, History and Summary of Significant
      Policies, page F-6

    History,
      page F-6

              6.

              Your
                disclosure states you accounted for the transaction between MW Medical,
                Inc. and Davi Skin, Inc. as a quasi-reorganization or reverse merger.
                This
                transaction appears to be a recapitalization rather than a
                quasi-reorganization or reverse merger. Please revise your disclosure
                accordingly here and in your subsequent filings on Form
                10-QSB.

    In
      response to this comment, the Company concurs that the transaction was a
      recapitalization, rather than a quasi-reorganization, and has replaced the
      reference to a quasi-reorganization with the term
“recapitalization.”

    Stock-based
      compensation page F-8

              7.

              Your
                response to our comment 13 indicates that you have updated your
                disclosures to include the information pursuant to paragraphs 46
                through
                48 of SFAS 123 as amended by SFAS 148. However, your response does
                not
                include what this disclosure will look like in your future filings,
                as
                previously requested, please show us how you intend to present this
                disclosure in your future filings.

    In
      response to this comment, the Company has added additional disclosure relating
      specifically to paragraphs 46 through 48 of SFAS 123 as amended by SFAS 148.
      Additionally, the Company anticipates that our disclosures related to this
      issue
      will be presented in future filings in a similar manner to how it is presented
      in Note 1“Stock-based
      compensation”.

        3

    Form.
      10-OSB for the Fiscal Quarter Ended June 30, 2005

    Comments
      applicable to your overall filing

              8.

              Please
                address the comments above in your interim Forms 10-QSB as well.

    In
      response to this comment, the Company has also addressed the previous comments
      where applicable in its prior and current 10QSB filings and has provided a
      redlined version of the 6-30-05 10QSB for your review.

    Financial
      Statements

    Statement
      of Stockholders’ Equity, page
      F-4

              9.

              We
                read your responses to our comments 16 and 17 from our letter dated
                September 19, 2005. Based on your response and revised disclosures-it
                is
                still unclear to us how you have reflected the two offerings in which
                you
                sold units consisting of two shares of your common stock and one
                warrant
                to purchase your common stock for $6.00 per unit. Please tell us
                what
                consideration you gave to the $5.25 market price of your stock on
                the date
                of offering and the $4.50 exercise price of each warrant in allocating
                the
                proceeds for each $6.00 unit. Supplementally, please provide us with
                your
                statement of stockholders' equity for the period from December 31,
                2004 to
                June 30, 2005. Please also include in your response any additional
                information that may be helpful to-us in understanding how you valued
                and
                allocated each component of the units
                sold.

    In
      response to this comment, the Company has supplementally provided the statement
      of stockholders’ equity for the period requested and has added footnote no. 5 to
      the financial statements for the quarters ended March 31 and June 30, 2005
      that
      provides the requested information. These transactions are reflected as an
      increase in cash, common stock and paid-in-capital, and also discussed in the
      footnotes. The financial statements for the quarter ended September 30, 2005
      will provide similar disclosures.

              10.

              Your
                response to our comment 18 from our letter dated September 19, 2005
                does
                not include what this disclosure will look like in your future filings.
                As
                previously requested, please show us how you intend to present in
                your
                future filings a note to the financial statements, which discusses
                your
                common stock issuances as presented in your statement of stockholders'
                equity and the activity you have included in Item 2. Unregistered
                Sales of
                Equity Securities and Use of
                Proceeds.

    In
      response to this comment, the Company has provided additional disclosure to
      show
      how it intends to present such a future note.

    Form
      8-K

               11.
               We read your response to our comment 20 from our
                letter dated September 19, 2005. An Item 4.02 Form 8-K should be
                filed
                within four business days of the triggering event. As

          4

                previously
                  requested, please file an Item 4.02 Form 8-K referencing each restatement
                  item, for which you have concluded a restatement is required. Refer
                  to
                  general instruction B(1) of Form
                  8-K.

    In
      response to this comment, the Company confirms that it has now filed the
      information required to be filed in a Form 8-K, Item 4.02 with regard to the
      referenced restatement in its recently filed 10QSB (rather than in a separate
      8K). It had felt that as these issues were still under examination that it
      would
      be preferable to file this and confirm the restatement upon completion of this
      review and the filing of the amended Forms 10-K and 10-Qs. The delay in filing
      was so that the restatements could be confirmed in this process and filed
      simultaneously with the annual and quarterly reports. Nonetheless, per your
      comment and consistent with SEC rules on filing such information when available
      to be filed in a 10QSB, the information has now been made available through
      a
      filing.

    If
      you
      have any questions regarding this comment letter, please feel free to contact
      me
      at

    702-312-6255.

    Sincerely,

    CANE
      CLARK LLP

    /s/
      Kyleen Cane
Kyleen
      Cane

        5

        Smith

                  &

               Company

        A
          Professional Corporation of Certified Public
          Accountants

    REPORT
      OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
      FIRM

    Board
      of
      Directors

    Daviskin,
      Inc. (formerly MW Medical, Inc.)

    (A
      Development Stage Company)

    We
      have
      audited the accompanying consolidated balance sheet of Daviskin, Inc. (formerly
      MW Medical, Inc.) (a Nevada development stage corporation) as of December 31,
      2004, and the related consolidated statements of operations, changes in
      stockholders' equity, and cash flows for the year ended December 31, 2004,
      and
      for the period of March 21, 2004 (date of inception) to December 31, 2004.
      These
      financial statements are the responsibility of the Company's management. Our
      responsibility is to express an opinion on these financial statements based
      on
      our audit.

    We
      conducted our audits in accordance with the standards of the Public Company
      Accounting Oversight Board (United States). Those standards require that we
      plan
      and perform the audit to obtain reasonable assurance about whether the
      consolidated financial statements are free of material misstatement. An audit
      includes examining, on a test basis, evidence supporting the amounts and
      disclosures in the consolidated financial statements. An audit also includes
      assessing the accounting principles used and significant estimates made by
      management, as well as evaluating the overall financial statement presentation.
      We believe that our audit provides