August 1, 2018

Terry Howlett
President and Chief Executive Officer
Skinvisible, Inc.
6320 South Sandhill Road, Suite 10
Las Vegas, NV 89120

       Re: Skinvisible, Inc.
           Amendment No. 3 to
           Preliminary Proxy Statement on Schedule 14A
           Filed July 25, 2018
           File No. 000-25911

Dear Mr. Howlett:

       We have reviewed your amended filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to comments in
our July 13,
2018 letter.

Amendment No. 3 to Preliminary Proxy Statement on Schedule 14A filed July 25,
2018

Unaudited Pro Form Condensed Combined Financial Statements, page 40

1.    We note your response to our prior comment 3 that you have provided more
complete
      financial information for Quoin for the year ended December 31, 2017 and
for the quarter
      ended March 31, 2018. However, it does not appear that you have provided
any
      additional financial information in this amendment. We also reiterate
that the financial
      information included on pages 40-44 is not sufficient to meet the
financial statement
      requirements, whether or not audited. Please provide financial statements
in accordance
      with U.S. generally accepted accounting principles, including notes to
the financial
 Terry Howlett
Skinvisible, Inc.
August 1, 2018
Page 2
       statements, for Quoin that meet the requirements of Item 14 of Schedule
14A and Item 17
       of Form S-4. In addition to providing those financial statements, and to
further help us
       consider whether or not providing audited financial statements for Quoin
in the proxy
       statement is not practicable, please confirm that, if the merger is
consummated, the
       audited financial statements for Quoin for the fiscal year ended 2017
will be provided in a
       timely filed Form 8-K.
2.     Please revise the consolidated pro forma financial information provided
to only include (i)
       a pro forma balance sheet as of the latest date required to be included
in the filing, which
       currently is March 31, 2018 and (ii) statements of operations for the
fiscal year ended
       December 31, 2017 and the latest interim period, which currently is the
quarter ended
       March 31, 2018. In this regard, delete all other pro forma statements
and periods
       presented. Please also revise this section to disclose how the merger
with Quoin is
       accounted for and how the accounting has been applied in the pro forma
financial
       information including the presentation of an adjustments column with
notes that explain
       any adjustments. Please also tell us what is meant by the statement on
page 40 that the
       unaudited pro forma condensed combined financial data is presented based
on
       Skinvisible's historical consolidated financial statements, "after
giving effect to the
       proposed spin-off of all of the business, assets and certain liabilities
of Skinvisible."
       Present the impact of the spin-off as an adjustment column with notes
explaining the
       adjustments or explain why such impact is not presented.
        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 Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442
with any
questions.


FirstName LastNameTerry Howlett
                                                             Division of
Corporation Finance
Comapany NameSkinvisible, Inc.
                                                             Office of
Healthcare & Insurance
August 1, 2018 Page 2
cc:       Scott Doney
FirstName LastName