CORRESP 1 filename1.txt PHOTOMEDEX, INC. 147 KEYSTONE DRIVE MONTGOMERYVILLE, PENNSYLVANIA 18936 TEL. NO. 215-619-3600 FACS. NO. 215-619-3209 January 24, 2005 VIA TELECOPIER AND FIRST CLASS MAIL (202) 942-9585 David Ritenour, Esq. Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street NW Washington, D.C. 20549 RE: PHOTOMEDEX, INC. REGISTRATION STATEMENT ON FORM S-3 FILE NO. 333-120921 Dear Mr. Ritenour: PhotoMedex is requesting by separate correspondence the effectiveness of the above-referenced registration statement. As requested in the Staff's correspondence, dated December 21, 2004, in connection with such request for acceleration, PhotoMedex hereby acknowledges the following: o should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; o the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and o the Company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Untied States. We have sent you a corresponding letter requesting that the effectiveness of the above-referenced Registration Statement be accelerated to Monday, January 24, 2005 at 5:00 p.m. (Eastern Time). PHOTOMEDEX, INC. By: /s/ Dennis M. McGrath -------------------------------- Dennis M. McGrath Chief Financial Officer cc: JEFFREY P. BERG, ESQ.