September 7, 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. 4 to
           Preliminary Proxy Statement on Schedule 14A
           Filed August 28, 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
August 1, 2018 letter.

Amendment No. 4 to Preliminary Proxy Statement on Schedule 14A filed August 28,
2018

Quoin Pharmaceuticals, Inc. Notes to Financial Statements (Unaudited)
1. Nature of Business
Transactions with Polytherapeutics, Inc. and its Principal Stockholders, page
36

1.     We note your statement that the company ascribes no value to the equity
interests of
       Polytherapeutics in the financial statements. Please revise this
statement to clarify how
       you accounted for the acquisition of Polytherapeutics and to include the
disclosures
       pursuant to ASC 805-10-50, as applicable.
 Terry Howlett
Skinvisible, Inc.
September 7, 2018
Page 2
4. Prepaid Expenses and Other Current Assets, page 38

2.    Please provide us the basis in the accounting literature for recording an
asset of $248,000
      shown as prepaid expenses and other current assets, which primarily
consist of direct,
      incremental legal fees relating to the Merger.
5. Unrecognized Research Consulting Costs, page 38

3.    Please provide us the basis in the accounting literature for recording
$636,314 shown as
      an asset called unrecognized research consulting costs and as a liability
called contractual
      commitments.
Unaudited Pro Forma Condensed Combined Financial Statements, page 47

4.    Please revise the headnote in this section to explain how you intend to
account for the
      merger, including which company is the accounting acquirer. Tell us the
basis in the
      accounting literature for your conclusion. Refer to ASC 805.
5.    With reference to our prior comment 2, please tell us why you excluded a
pro forma
      combined statement of operations for the fiscal year ended December 31,
2017. In
      addition, please remove the unaudited pro forma statement of cash flows
on page 50.
6.    Please provide disclosure in notes to the pro forma combined financial
statements to
      explain why the only adjustment is the one for $381,999 from common stock
to additional
      paid in capital.
        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.



                                                            Sincerely,
FirstName LastNameTerry Howlett
                                                            Division of
Corporation Finance
Comapany NameSkinvisible, Inc.
                                                            Office of
Healthcare & Insurance
September 7, 2018 Page 2
cc:       Scott Doney
FirstName LastName