DREIER LLP Attorneys at Law 499 Park Avenue Valerie A. Price New York, New York 10022 Direct Dial: (212) 328-6144 Tel: (212) 328-6100 Direct Fax: (212) 652-3789 Facsimile: (212) 328-6101 Partner vprice@dreierllp.com October 24, 2005 Securities and Exchange Commission 450 Fifth Street N.W. Washington, DC 20549 Re: Electro-Optical Sciences, Inc. Registration Statement on Form S-1 Registration Statement on Form 8-A Request for Acceleration File No. 333-125517 Dear Sir or Madam: On behalf of Electro-Optical Sciences, Inc. (the "Company"), we enclose an acceleration request executed by the Company which is being filed pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended. On June 3, 2005, the Company filed with the Securities and Exchange Commission a Registration Statement on Form S-1 (Registration No. 333-125515) (the "Registration Statement") relating to the offering of up to 3,000,000 shares of the common stock of the Company. The Company filed an Amendment No. 1 to the Registration Statement on July 15, 2005, filed an Amendment No. 2 to the Registration Statement on August 8, 2005, filed an Amendment No. 3 to the Registration Statement on August 10, 2005, filed an Amendment No. 4 to the Registration Statement on September 27, 2005 and an Amendment No. 5 to the Registration Statement on October 12, 2005. The Company's Registration Statement on Form S-1 has been assigned to Russell Mancuso, Branch Chief, Division of Corporation Finance, for review. The Company has requested the staff to waive the time period requirements for requesting acceleration of the effective date and would like the Registration Statement on Form S-1 and the Registration Statement on Form 8-A to be declared effective at 4:00 p.m. (Eastern Daylight Savings Time) on October 24, 2005 or as soon thereafter as possible. If you have any questions or require further information, please call the undersigned at (212) 328-6144 Very truly yours, /s/ Valerie A. Price Valerie A. Price VAP/ma Enclosure cc: David C. Peck, Esq.