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QUICK
LAW GROUP PC

1035
PEARL STREET

SUITE
403

BOULDER,
CO 80302

Phone:
720.259.3393

Facsimile:
303.845.7315

June
13, 2024

VIA
EDGAR

Division
of Corporation Finance

Office
of Industrial Applications and Services

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

    Attention:
    Tracey
Houser, Esq.

    Terence
    O’Brien, Esq.

    Re:
    NEXGEL,
    Inc.

    Form
    10-K for the Fiscal Year Ended December 31, 2023

    Filed
    April 10, 2024

    File
    No. 001-41173

Ladies
and Gentlemen,

On
behalf of NEXGEL, Inc. (the “Company”), we are writing to respond to the comments set forth in the comment letter
of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated
June 3, 2024 (the “Comment Letter”), to Adam Drapczuk, Chief Financial Officer of the Company, relating to the above
referenced Form 10-K for the fiscal year ended December 31, 2023 (the “Original Report”). In connection with this
response to the Comment Letter, the Company is contemporaneously filing via EDGAR an amendment to the Original Report (the “Amendment”)
with the Commission, responding to the Staff’s comments in the Comment Letter and amending the Original Report.

The
following is the Company’s response to the Comment Letter. The Company’s response is numbered to correspond to the Staff’s
comment as numbered in the Comment Letter. For your convenience, the Staff’s comment contained in the Comment Letter has been restated
below in its entirety, with the Company’s response set forth immediately under such comment.

    U.S. Securities and Exchange Commission

June 13, 2024

Page 2

Form
10-K for Fiscal Year Ended December 31, 2023

Item 9A. Controls and Procedures, page 25

    1.
    Please
    amend your filing to provide management’s annual report on internal control over financial reporting. Ensure you include a
    statement of management’s responsibility for establishing and maintaining adequate internal control over financial reporting
    and a statement identifying the framework used by management to evaluate the effectiveness of internal control over financial reporting.
    Also, include management’s assessment of the effectiveness of internal control over financial reporting as of December 31,
    2023, including a statement as to whether or not internal control over financial reporting is effective. Refer to Item 308(a) of
    Regulation S-K.

Response:
In the Amendment and in accordance with Item 308(a) of Regulation S-K, the Company included a statement of management’s responsibility
for establishing and maintaining adequate internal control over financial reporting and a statement identifying the framework used by
management to evaluate the effectiveness of internal control over financial reporting. Additionally, the Company included management’s
assessment of the effectiveness of internal control over financial reporting as of December 31, 2023 and concluded that the Company’s
internal control over financial reporting was effective as of December 31, 2023 to provide reasonable assurance regarding the reliability
of financial reporting and the preparation of financial statements in accordance with accounting principles generally accepted in the
United States of America.

    2.
    In
    light of the missing internal control over financial reporting disclosures, please re-evaluate your conclusion regarding the effectiveness
    of disclosure controls and procedures. Also address this comment for your March 31, 2024 Form 10-Q’s conclusion for your disclosure
    controls and procedures.

Response:
In light of the Amendment, the Company’s management re-evaluated its conclusion regarding the effectiveness of the Company’s
disclosure controls and procedures as of December 31, 2023 and March 31, 2024, respectively. The Company notes that the Company’s
management inadvertently failed to include management’s annual report on internal control over financial reporting in the Original
Report. The omission of the disclosure had no impact on the consolidated financial statements and other disclosures contained in the
Original Report or in the Form 10-Q for the quarterly period ended March 31, 2024. Management is aware of its responsibility for establishing
adequate internal controls over financial reporting, had such internal controls in place at that time, and complied with the procedures
established by the internal controls framework. The specific disclosure item was inadvertently omitted from the Original Report as the
Company had previously relied on an exemption established by the SEC for newly public companies that allowed the Company to exclude management’s
report on internal control over financial reporting. As such, management concluded that the Company’s disclosure controls and procedures
were effective as of December 31, 2023 and March 31, 2024.

We
hope the above responses and the revised disclosure contained in the Amendment have addressed appropriately all of the Staff’s
comments. Should you require any further information or have any questions, please do not hesitate to contact the undersigned at (720)
259-3393.

    U.S. Securities and Exchange Commission

June 13, 2024

Page 3

    Sincerely,

    QUICK
    LAW GROUP P.C.

    /s/
    Jeffrey M. Quick

    Jeffrey
    M. Quick

    cc:
    Adam
    Levy, NEXGEL, Inc.

    Adam
    Drapczuk, NEXGEL, Inc.