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Journey Medical Corporation

9237 E Via de Ventura Blvd., Suite 105

Scottsdale, AZ 85258

VIA EDGAR

January 15, 2026

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attn: Daniel Crawford

 Re: Journey Medical Corporation

Registration
Statement on Form S-3

File No. 333-292758

Request for Acceleration of Effective
Date

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Journey Medical Corporation (the “Company”) hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
on Form S-3 (the “Registration Statement”) so that the Registration Statement will be declared effective as of 4:00
p.m. Eastern time, on January 20, 2026, or as soon as practicable thereafter. The Company hereby authorizes Rakesh Gopalan or David S.
Wolpa, both of whom are attorneys at the Company’s outside legal counsel, Troutman Pepper Locke LLP, to orally modify or withdraw
this request for acceleration.

Once the Registration Statement
has been declared effective, please orally confirm that event with Mr. Gopalan at (704) 916-2374 or Mr. Wolpa at (704) 916-2375.

Thank you for your assistance
in this matter.

    Very truly yours,

    Journey Medical Corporation

    /s/ Joseph Benesch

    Name: Joseph Benesch

    Title: Chief Financial Officer

cc (via email):  Rakesh Gopalan and David Wolpa, Troutman Pepper
Locke LLP

December 30, 2025
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Draft Registration Statement on Form S-3
Submitted December 30, 2025
CIK No. 0001867066
Dear Claude Maraoui:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement and non-public draft
submission on EDGAR at least two business days prior to the requested effective date and
time. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Daniel Crawford at 202-551-7767 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:David S. Wolpa, Esq.

September 9, 2024
Claude Maraoui
Chief Executive Officer
Journey Medical Corporation
9237 E Via de Ventura Blvd, Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed March 29, 2024
File No. 001-41063
Dear Claude Maraoui:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Rakesh Gopalan, Esq.

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August 22, 2024

VIA EDGAR

Doris Stacey Gama and Suzanne Hayes

Division of Corporation Finance

Office of Life Sciences

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Journey Medical Corporation

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

Filed March 29, 2024

File No. 001-41063

Ladies and Gentlemen:

We are writing to respond
to the comment provided by the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and
Exchange Commission in your letter dated August 21, 2024, relating to the Journey Medical Corporation (“we”, “Journey”,
or the “Company”) Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed on March 29, 2024 (the
 “Form 10-K”).

For ease of review, we have
set forth below the Staff’s comment in bold type, followed by the Company’s response thereto.

Form 10-K for the Fiscal Year Ended December
31, 2022

Item 1C. Cybersecurity

Cybersecurity Governance, page 61

We note that leaders from your information security, compliance
and legal team oversee cybersecurity risk management. Please revise future filings to provide the relevant expertise of such persons or
members in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.

Response to Comment:

The Company acknowledges the
Staff’s comment and confirms that the Company will revise future filings to provide the relevant expertise of such persons or members
in such detail as is necessary to fully describe the nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.

Securities and Exchange Commission

Division of Corporation Finance

August 22, 2024

Page 2 of 2

⁕⁕⁕

Should any member of the Staff
have questions regarding our responses to the comments set forth above or need additional information, please do not hesitate to call
me at (480) 434-6670. Thank you for your assistance in this matter.

    Very truly yours,

    /s/ Joseph Benesch

    Joseph Benesch

    Chief Financial Officer

 cc (electronic): Ramsey Alloush, General Counsel

Rakesh Gopalan, Troutman Pepper Hamilton
Sanders LLP

David S. Wolpa, Troutman Pepper Hamilton
Sanders LLP

August 21, 2024
Claude Maraoui
Chief Executive Officer
Journey Medical Corporation
9237 E Via de Ventura Blvd, Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed March 29, 2024
File No. 001-41063
Dear Claude Maraoui:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K
Item 1C. Cybersecurity
Cybersecurity Governance, page 61
1.We note that leaders from your information security, compliance and legal team oversee
cybersecurity risk management. Please revise future filings to provide the relevant
expertise of such persons or members in such detail as is necessary to fully describe the
nature of the expertise as required by Item 106(c)(2)(i) of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff.
            Please contact Doris Stacey Gama at 202-551-3188 or Suzanne Hayes at 202-551-3675
with any other questions.

August 21, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Rakesh Gopalan, Esq.

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January 24, 2023

VIA EDGAR

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Journey Medical Corporation

    Registration Statement on Form S-3

    File No. 333-269079

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, Journey Medical Corporation (the “Company”) hereby requests that the
Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration
Statement on Form S-3 (the “Registration Statement”) so that the Registration Statement will be declared effective
as of 4:30 p.m. Eastern time, on January 26, 2023, or at such other time as the Company or its outside counsel, McGuireWoods
LLP, may request via a telephone call to the staff of the Commission.

Once the Registration Statement
has been declared effective, please orally confirm that event with Rakesh Gopalan of McGuireWoods LLP at (704) 343-2275, or in his absence,
David Wolpa of McGuireWoods at (704) 343-2185.

Thank you for your assistance
in this matter.

    Very truly yours,

    /s/ Claude Maraoui

    Name:   Claude Maraoui

    Title:    President and Chief Executive Officer

cc:       Rakesh Gopalan, McGuireWoods LLP

United States securities and exchange commission logo
January 5, 2023
Ramsey Alloush
General Counsel
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Registration Statement on Form S-3
Filed December 30, 2022
File No. 333-269079
Dear Ramsey Alloush:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Alan Campbell at 202-551-4224 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       David S. Wolpa

United States securities and exchange commission logo
November 10, 2021
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed November 8, 2021
File No. 333-260436
Dear Mr. Maraoui:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed November 8, 2021
Recent Development, page 3
1.We note that you disclose your expectation for revenue for the three months ended
September 30, 2021, without any additional financial information.  We believe your
current disclosure provides an incomplete picture of your expected results of operations.
Please revise your disclosure to provide additional quantitative information for the quarter
(e.g., Income (loss) from operations, etc.).  In addition, we note your statement that your
“actual results may vary materially from the estimated preliminary results....”  If you
choose to disclose preliminary results, you should be able to assert that the actual results
are not expected to differ materially from these preliminary results.  Accordingly, please
remove this statement as it implies that investors should not rely on the information

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 November 10, 2021 Page 2
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
November 10, 2021
Page 2
presented.  Lastly, your reference to fiscal year 2021 appears to be in error.  Please revise
your reference so that it refers to the period for which results are being discussed or
explain the purpose of this sentence.
            You may contact Michael Fay at 202-551-3812 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Gary Guttenberg at 202-551-6477 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark F. McElreath, Esq.

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November 10, 2021

VIA EDGAR

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

    B. RILEY
    SECURITIES, INC.

    By:
     /s/ Jonathan C. Rich

    Name:
    Jonathan
    C. Rich

    Title:
    Senior Managing Director –
    Head of Investment Banking Solutions

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90 Park Avenue

New York, NY 10016

212-210-9400 | Fax: 212-210-9444

    Mark F. McElreath
    Direct Dial: 212-210-9595
    Email: mark.mcelreath@alston.com

November 10, 2021

VIA: ELECTRONIC MAIL

Mr. Gary Guttenberg

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Journey Medical Corporation

    Registration Statement on Form S-1

    Filed November 8, 2021

    File No.: 333-260436

Dear Mr. Guttenberg:

On behalf of Journey Medical
Corporation, a Delaware corporation (the “Company”), we hereby respond to comments from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission received in a letter dated November 10, 2021, relating to the Company’s Amendment
No. 1 to Registration Statement on Form S-1 filed on November 8, 2021.

The Company is concurrently
publicly filing via EDGAR an amendment to the Registration Statement on Form S-1 (the “Registration Statement”).
All references to page numbers in the Company’s responses refer to page numbers in the Registration Statement.

Request 1 – Recent Development, page 3:

We note that you disclose your expectation for
revenue for the three months ended September 30, 2021, without any additional financial information. We believe your current disclosure
provides an incomplete picture of your expected results of operations. Please revise your disclosure to provide additional quantitative
information for the quarter (e.g., Income (loss) from operations, etc.).  In addition, we note your statement that your
“actual results may vary materially from the estimated preliminary results....” If you choose to disclose preliminary
results, you should be able to assert that the actual results are not expected to differ materially from these preliminary results.
Accordingly, please remove this statement as it implies that investors should not rely on the information presented.  Lastly,
your reference to fiscal year 2021 appears to be in error.  Please revise your reference so that it refers to the period for which
results are being discussed or explain the purpose of this sentence.

November 10, 2021

Page 2

Response:

The Company has revised its disclosure on page 3
relating to expectation for revenue for the three months ended September 30, 2021 to provide additional quantitative information
for the quarter. The Company has also revised the disclosure to indicate that actual results are not expected to vary materially from
the estimated preliminary results, and removed reference to fiscal year 2021.

    Sincerely,

    ALSTON & BIRD LLP

    /s/ Mark F. McElreath

    Mark F. McElreath, Esq.

    cc:
    Claude Maraoui, President and CEO

    Journey Medical Corporation

    Stephen E. Older, Esq. and Rakesh Gopalan, Esq.

McGuireWoods LLP

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November 10, 2021

VIA EDGAR

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, as amended

    File No.  333-260436

Ladies and Gentlemen:

Journey Medical Corporation
(the “Company”) hereby requests, pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933,
as amended, that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective
at 4:00 p.m. EST 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.

Please
contact Mark McElreath of Alston & Bird LLP, the Company’s counsel, at (212) 210-9595, as soon as the Registration
Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

  Journey Medical Corporation

  By:
  /s/ Claude Maraoui

  Name:
  Claude Maraoui

  Title:
  President, Chief Executive Officer and Director

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90 Park
Avenue

New York, NY 10016

212-210-9400 | Fax: 212-210-9444

    Mark F. McElreath
    Direct Dial: 212-210-9595
    Email: mark.mcelreath@alston.com

November 8, 2021

VIA: ELECTRONIC MAIL

Mr. Gary Guttenberg

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Journey Medical Corporation

    Registration Statement on Form S-1

    Filed November 8, 2021

    File No.: 333-260436

Dear Mr. Guttenberg:

On behalf of Journey Medical
Corporation, a Delaware corporation (the “Company”), we hereby respond to comments from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission received in a letter dated November 1, 2021, relating to the Company’s Registration
Statement on Form S-1 submitted on October 22, 2021.

The Company is concurrently
publicly filing via EDGAR an amendment to the Registration Statement on Form S-1 (the “Registration Statement”).
All references to page numbers in the Company’s responses refer to page numbers in the Registration Statement.

Request 1 – Use of Non-GAAP Measures,
page 63:

We note your COVID-19 sales force savings
adjustment is due to the fact that you did not incur salary expense related to your field sales forces.  As such, it appears this
Non-GAAP adjustment is for an amount that is not in your historical GAAP financial statements and was not part of your operating
results for that period, which would be prohibited by Item10(e)(2) of Regulation S-K.  Please revise your presentation
accordingly.

Response:

In response to the Staff’s comment, the
Company has revised its disclosure regarding the impact of COVID-19 on the Company’s expenses relating to its field sales forces
on page 64.

November 8, 2021

Page 2

Request 2 – Product Licensing Agreements
and Acquisitions, page 76:

With respect to your Accutane and Exelderm Agreements, please
revise the references to "low-double digits" to provide a more defined range of royalties that does not exceed ten
percentage points (e.g., teens or low teens).

Response:

In response to the Staff’s comment, the
Company has revised its disclosures relating to the royalty ranges for Accutane and Exelderm on page 78.

    Sincerely,

    ALSTON & BIRD LLP

    /s/ Mark F. McElreath

    Mark F. McElreath, Esq.

    cc:
    Claude Maraoui, President and CEO

    Journey Medical Corporation

    Stephen E. Older, Esq. and Rakesh Gopalan, Esq.

McGuireWoods LLP

United States securities and exchange commission logo
November 1, 2021
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Registration Statement on Form S-1
Filed October 22, 2021
File No. 333-260436
Dear Mr. Maraoui:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1
Use of Non-GAAP Measures, page 63
1.We note your COVID-19 sales force savings adjustment is due to the fact that you did not
incur salary expense related to your field sales forces.  As such, it appears this Non-GAAP
adjustment is for an amount that is not in your historical GAAP financial statements and
was not part of your operating results for that period, which would be prohibited by Item
10(e)(2) of Regulation S-K.  Please revise your presentation accordingly.
Product Licensing Agreements and Acquisitions, page 76
2.With respect to your Accutane and Exelderm Agreements, please revise the references to
"low-double digits" to provide a more defined range of royalties that does not exceed ten
percentage points (e.g., teens or low teens).

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 November 1, 2021 Page 2
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
November 1, 2021
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Michael Fay at (202) 551-3812 or Kevin Vaughn at (202) 551-3494 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gary Guttenberg at (202) 551-6477 or Jeffrey Gabor at (202) 551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark F. McElreath, Esq.

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90 Park Avenue

New York, NY 10016

212-210-9400 | Fax: 212-210-9444

    Mark F. McElreath
    Direct Dial: 212-210-9595
    Email: mark.mcelreath@alston.com

October 22, 2021

VIA: ELECTRONIC MAIL

Mr. Gary Guttenberg

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Journey Medical Corporation

    Registration Statement on Form S-1

    CIK No. 0001867066

Dear Mr. Guttenberg:

On
behalf of Journey Medical Corporation, a Delaware corporation (the “Company”), we hereby respond to
comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
 “Commission”) received in a letter dated October 18, 2021, relating to the Company’s Amendment No. 2
to Draft Registration Statement on Form S-1 submitted on October 5, 2021.

The Company is
concurrently publicly filing via EDGAR a Registration Statement on Form S-1 (the “Registration
Statement”). All references to page numbers in the Company’s responses refer to page numbers in the Registration
Statement.

Use of Non-GAAP Measures, page 63

Comment 1:

We note that you have excluded R&D license
acquisition costs in the amount of $10 million to arrive at Non-GAAP Adjusted EBITDA.  Please tell us your consideration of the guidance
in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations for this adjustment.  In this regard,
you state on page 70, for example, that an important part of your growth strategy is to identify new business development opportunities,
including development stage and commercial drugs that you may acquire from other pharmaceutical companies.

Response:

In response to the Staff’s comment,
the Company has removed from its calculation of Non-GAAP Adjusted EBITDA the exclusion of R&D license
acquisition costs, and instead added footnote 1 on page 64, noting that the Non-GAAP adjusted EBITDA includes the $10.0 million
related to the acquisition of the Company's R&D license.

October 22, 2021

Page 2

Comment 2:

Please clarify for us in greater detail the COVID-19
sales force savings Non-GAAP adjustment of $1,426 and the related description.

Response:

In response to the Staff’s comment,
the Company has added footnote 2 on page 64 regarding the adjustment for COVID-19
sales force savings. Specifically, the Company has noted that for the period ending June 30, 2020, the Company did not incur
costs related to its field sales force, as a result of subsidies received by the professional employer organization that furnishes
the sales force, resulting in a one-time non-recurring savings. As such, no savings were incurred in either calendar year 2019 or
for the six months ended June 30, 2021.

Accutane Agreement, page 75

Comment 3:

We note that you entered into a license and
supply agreement for Accutane® with a third party.  Please identify the third party or tell us why this
information is not material.

Response:

In response to the Staff’s comment, the
Company has identified Dr. Reddy’s Laboratories Ltd. as the Accutane licensor on page 78, F-37, and on page II-3. In addition, the Company is no longer redacting the licensor’s name in Exhibit 10.7.

    Sincerely,

    ALSTON & BIRD LLP

    /s/ Mark F. McElreath

    Mark F. McElreath

cc:           Claude Maraoui, President and CEO

     Journey Medical Corporation

Stephen E. Older, Esq. and Rakesh Gopalan, Esq.

     McGuireWoods LLP

United States securities and exchange commission logo
October 18, 2021
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted October 5, 2021
CIK No. 0001867066
Dear Mr. Maraoui:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 filed October 5, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Use of Non-GAAP Measures, page 63
1.We note that you have excluded R&D license acquisition costs in the amount of $10
million to arrive at Non-GAAP Adjusted EBITDA.  Please tell us your consideration of
the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations for this adjustment.  In this regard, you state on page 70, for
example, that an important part of your growth strategy is to identify new business
development opportunities, including development stage and commercial drugs that
you may acquire from other pharmaceutical companies.

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 October 18, 2021 Page 2
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
October 18, 2021
Page 2
2.Please clarify for us in greater detail the COVID-19 sales force savings Non-GAAP
adjustment of $1,426 and the related description.
Business
Accutane Agreement, page 75
3.We note that you entered into a license and supply agreement for Accutane® with a third
party.  Please identify the third party or tell us why this information is not material.
            You may contact Michael Fay at 202-551-3812 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Gary Guttenberg at 202-551-6477 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark F. McElreath, Esq.

United States securities and exchange commission logo
September 17, 2021
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted September 2, 2021
CIK No. 0001867066
Dear Mr. Maraoui:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1 submitted September 2, 2021
Capitalization, page 52
1.In response to prior comment nine, we note you changed the total label from total
capitalization to total liabilities and stockholders' equity.  Since total liabilities and
stockholders' (deficit) is $72,725,000 according to page F-2, and not $32,627,000 as
presented here, it appears that the label should remain total capitalization.  Please revise
accordingly.

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 September 17, 2021 Page 2
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
September 17, 2021
Page 2
Consolidated Financial Statements
Revenue Recognition, page 59
2.We have reviewed your revised disclosure in response to prior comment 19 and it does not
appear that you have disclosed sufficient information to enable financial statement users
to understand the nature, amount, timing, and uncertainty of revenue and cash flows
arising from contracts with customers.  Specifically, it does not appear that you have
provided the qualitative and quantitative information about the significant judgements
(i.e., inputs and assumptions) and changes in the judgments, as set forth in ASC 606-10-
50-20, and 50-1 though 50-2, as it relates to the determination of the transaction price,
etc.  Please revise your disclosure accordingly.
            You may contact Michael Fay at 202-551-3812 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Gary Guttenberg at 202-551-6477 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark F. McElreath, Esq.

United States securities and exchange commission logo
August 20, 2021
Claude Maraoui
Chief Executive Officer, President and Director
Journey Medical Corporation
9237 E Via de Ventura Blvd., Suite 105
Scottsdale, AZ 85258
Re:Journey Medical Corporation
Draft Registration Statement on Form S-1
Submitted July 22, 2021
CIK No. 0001867066
Dear Mr. Maraoui:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted July 22, 2021
Industry and Market Data, page ii
1.We note your statements that certain data and beliefs and estimates based on third party
data may not be reliable and that you do not guaranty the accuracy or completeness of
such information included in the prospectus. Such statements may imply an inappropriate
disclaimer with respect to third-party information. Please revise to remove such
statements and any implication that investors are not entitled to rely on the information
included in the prospectus.

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 August 20, 2021 Page 2
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
August 20, 2021
Page 2
Prospectus Summary, page 1
2.We note your disclosure that you acquired an anti-itch product from a third
party.  Please identify the third party or tell us why this information is not material.
3.Please balance your Summary by providing enhanced discussion of the material risks to
your business and this offering. In this regard, balance the discussion of your major
marketed products with equally prominent disclosure regarding the current status of your
intellectual property rights.
Risks Related to our Relationship with Fortress Biotech, Inc., page 4
4.Please clarify whether the company will be a “controlled company” under the definition of
the applicable listing exchange and provide applicable disclosure to the extent appropriate.
Implications of Being an Emerging Growth Company, page 5
5.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
Risk Factors
Our charter documents and Delaware law could discourage takeover attempts and other
corporate governance changes., page 40
6.Please revise to break out under a separate heading your discussion of your
exclusive forum provision and note the applicability of the provision to actions arising
under the Securities Act or Exchange Act and any enforceability or other concerns
associated therewith.
Use of Proceeds, page 46
7.We note your disclosure that you intend to use portions of the proceeds of this offering to:
(i) pursue both development stage and commercial opportunities; (ii)
the commercialization expenses related to existing products; (iii) the launch of new
products; (iv) development costs associated DFD-29; (v) new development stage
products; and (vi) pursue acquisition opportunities.  Please specify what amounts will be
allocated to each of these uses.  If any material amounts of other funds are necessary to
accomplish the specified purposes, state the amounts and sources of other funds needed
for each specified purpose and the sources.  For guidance, please refer to Item 504 of
Regulation S-K.
8.To the extent you intend to use a portion of the net proceeds to repay debt, please revise to
provide the information required by Instruction 4 to Item 504 of Regulation S-K, or
provide appropriate cross references.

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 August 20, 2021 Page 3
 FirstName LastNameClaude Maraoui
Journey Medical Corporation
August 20, 2021
Page 3
Capitalization , page 51
9.Please address the following:
•Revise to place double lines under the cash amount to indicate that cash is not part of
capitalization.
•Clarify how you determined the amount of total capitalization included at the bottom
of the table.  In this regard, we note it does not include the listed liabilities.
•We note the Convertible Class A Preferred Stock is presented under Stockholders’
Equity heading here on page 51, but on page F-21 you disclose that the Series A
preferred issued in February 2021 will be accounted for as a liability.  Please revise
your presentation accordingly.
•Revise this section to address the equity issuance or cash payment to Dr. Reddy's
Laboratories, Ltd. that would be triggered at the close of an initial public offering
meeting the criteria you described on page F-22.
Business
Product Licensing Agreements and Acquisitions, page 68
10.Please revise your description of each agreement referenced in this section, as applicable,
to disclose the duration and termination provisions and the royalty term and any royalty
term expiration provisions.
11.We note your description of your DFD-29 agreement.  Please revise to clarify what you
mean by “lower double digits to the lower teen digits” so that investors understand the
potential range of royalty payments in a range not to exceed ten percent.  If the range is
more than ten percent, please provide a range within ten percent for each tier or disclose
the number of tiers.
12.We note your description of the Targadox agreement.  Please revise to clarify the material
terms of the revenue sharing arrangement.
Intellectual Property, page 70
13.Please revise to disclose the type of patent protection granted, the expected expiration
dates of your pending applications, and the applicable jurisdiction of your patents and
pending applications.
Research and Development, page 70
14.We note your discussion on page 70 regarding the Phase II study.  Please present the
supporting data that you used to draw the conclusion that the study showed that DFD-29
40mg had "statistical significance to both placebo and the active control," disclose the p-
value used to measure statistical significance, and provide a brief explanation how p-
values are used to measure statistical significance.  Additionally, please revise to clarify
whether you observed any serious adverse events that were related or possibly related to
DFD-29.

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 August 20, 2021 Page 4
 FirstName LastNameClaude Maraoui
Journey Medical Corporation
August 20, 2021
Page 4
Executive Compensation, page 87
15.Please revise to include a third named executive officer if their compensation exceeded
$100,000 in 2020.  Refer to Item Item 402(m)(2) or Regulation S-K.
CERTAIN RELATIONSHIPS AND RELATED-PARTY TRANSACTIONS, page 94
16.Please provide a brief description of the material terms of your Shared Services
Agreement.
Consolidated Financial Statements
Note 1. Organization and Plan of Business Operations, page F-7
17.Revise to disclose how expenses incurred by Fortress on behalf of Journey have been
accounted for, including any expense allocations as well as any stock-based compensation
related to Fortress equity instruments for employees that performed work on behalf of
Journey.
Revenue Recognition , page F-8
18.We note that payment is due within months of when a customer is invoiced.  Please revise
your disclosure to provide more specificity with regard to significant payment terms.
Refer to ASC 606-10-50-12.
19.We note you use an expected value method to estimate variable consideration and whether
the transaction price is constrained.  Please disclose information about the inputs and
assumptions for determining the transaction price, etc., as set forth in ASC 606-10-50-20.
Also refer to ASC 606-10-50-1 and 50-2.
20.Please provide a description of your coupons, price protection and consideration payable
to the customer that is included in your contracts with customers, as required by ASC 606-
10-50-12(d). Revise to separately quantify your rebates, sales discounts, and sales returns.
To the extent you believe such deductions are not material for disclosure, provide us with
amounts for the periods presented as part of your response. To the extent you experience
significant out of period adjustments to any of these deductions, revise to provide a
rollforward which separately quantifies such adjustments.
Intangible Assets, page F-9
21.Please revise to disclose your accounting policy related to potential milestone and royalty
payments, etc., under your asset purchase agreements.  For example, address when you
will record potential payments and how you will account for the payments.
Note 7. Accrued Expenses, page F-14
22.Please clarify whether accrued coupon reserve is a contract liability under ASC 606-10-20
and, if so, provide the disclosures required by ASC 606-10-50-8(b).

 FirstName LastNameClaude Maraoui
 Comapany NameJourney Medical Corporation
 August 20, 2021 Page 5
 FirstName LastName
Claude Maraoui
Journey Medical Corporation
August 20, 2021
Page 5
            You may contact Michael Fay at 202-551-3812 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Gary Guttenberg at 202-551-6477 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark F. McElreath, Esq.