Nu Skin Enterprises, Inc.
                             75 West Center Street
                               Provo, Utah 84601


                                October 25, 1999

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549

         Re:      Nu Skin Enterprises, Inc.
                  Registration Statement on Form S-3
                  File No. 333-78415

Ladies and Gentlemen:

         Pursuant to Rule 477 of the  General  Rules and  Regulations  under the
Securities Act of 1933, Nu Skin  Enterprises,  Inc.  hereby applies for an order
granting the  immediate  withdrawal  of its  Registration  Statement on Form S-3
(File No. 333-78415), together with all exhibits. The Registration Statement was
originally filed with the Commission on May 14, 1999.

         Pursuant to the Registration Statement, Nu Skin Enterprises proposed to
register certain shares of its Class A Common Stock,  $.001 par value per share,
for issuance to the public.  Nu Skin  Enterprises,  upon  consultation  with the
underwriters,  has decided  not to proceed  with the  offering at this time.  No
securities have been sold under the  Registration  Statement and all activity in
pursuit of the offering has been discontinued.

         Nu Skin  Enterprises  requests  that  the  Commission  issue  an  order
granting  the  withdrawal  of the  Registration  Statement  effective as soon as
possible.

                                  Sincerely,

                                  Nu Skin Enterprises, Inc.

                                  By:  /s/ Steven J. Lund
                                       ------------------------
                                       Steven J. Lund

                                  Its: President and Chief Executive Officer