<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                             October 1, 2021

       Ron Bentsur, M.B.A.
       Chairman and Chief Executive Officer
       Nuvectis Pharma, Inc.
       1 Bridge Plaza
       Suite 275
       Fort Lee, NJ 07024

                                                        Re: Nuvectis Pharma,
Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted September
20, 2021
                                                            CIK No. 0001875558

       Dear Mr. Bentsur:

             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 20, 2021

       Prospectus Summary, page 1

   1.                                                   We note the pipeline
table added to page 2. Please revise to include a column for Phase 3
                                                        clinical trials.
 Ron Bentsur, M.B.A.
FirstName  LastNameRon Bentsur, M.B.A.
Nuvectis Pharma, Inc.
Comapany
October    NameNuvectis Pharma, Inc.
        1, 2021
October
Page 2 1, 2021 Page 2
FirstName LastName
2.       We note your statement on page 6 and elsewhere that NXP900 has
demonstrated high
         potency and selectivity, and on page 72 you state that treatment with
NXP900 results in
         increased antitumor efficacy and tolerability in vivo in syngeneic
murine cancer models
         and xenografts. Please remove all statements that present your
conclusions regarding the
         efficacy of your product candidate as this is a determination within
the authority of the
         U.S. Food and Drug Administration and comparable regulatory bodies.
3.       On page 7 you state that treatment with NXP900 resulted in increased
anti-tumor efficacy
         and tolerability in both syngeneic murine cancer models and
xenografts, demonstrating
         significant therapeutic advantages over dasatinib, including improved
tumor growth
         inhibition, survival and duration of response. We also note on page 73
that at least one
         mouse model reflected a head-to-head study of dasatinib. Please revise
to state whether
         each of the comparisons to dasatinib reflects the results of a
head-to-head comparison. If
         not, please remove such comparison as comparisons to available
products and other
         product candidates are not appropriate unless you have conducted
head-to-head trials.
Capitalization, page 48

4.       We note your response to our prior comment 10 and reissue in part.
Please revise to also
         include the conversion of the preferred A shares as part of the pro
forma balance, rather
         than as part of the pro forma as adjusted balance as you currently
present, to properly
         reflect the offering effect in the capitalization table here, and also
to properly reflect the
         dilution to new investors participating in this offering in the
dilution table at page 50.
Preclinical drug discovery and validation, page 69

5.       We note your response to prior comment 18. Please revise to clarify
the scope, size, and
         design of each preclinical study referenced in this section; whether
the studies were
         powered to show statistical significance; and revise your
characterizations of the
         preclinical trials to discuss the data, rather than drawing
conclusions from the results.
Exhibits

6.       We note your response to our prior comment number 21, where you state
you do not plan
         to enter indemnification agreements with your directors and officers.
Given this response
         and that references to an indemnification agreement remain on pages
F-15 and F-16,
         please clarify whether any such agreements are already in place.
 Ron Bentsur, M.B.A.
FirstName  LastNameRon Bentsur, M.B.A.
Nuvectis Pharma, Inc.
Comapany
October    NameNuvectis Pharma, Inc.
        1, 2021
October
Page 3 1, 2021 Page 3
FirstName LastName
       You may contact Li Xiao at 202-551-4391 or Brian Cascio at 202-551-3676
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Margaret Schwartz at 202-551-7153 or Jeffrey Gabor at 202-551-2544 with any
other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Life
Sciences
cc:      Matthew W. Mamak, Esq.
</TEXT>
</DOCUMENT>
