SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

        March 25 , 2014

Via E-mail
Mr. Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 North 3rd Street
Bismarck, ND 58501

 Re: ADM Endeavors,  Inc.
  Amendment No. 2  to Registration Statement on Form S -1
  Filed March 19 , 2014
 File No. 333 -191618

Dear Mr. Mees :

We have reviewed the amended  filing and have the  comments  below .

Dealer Prospectus Delivery Obligation, page 2

1. Refer to comment 13 in our February 6, 2014 letter.  We note that the revised date of March
19, 2014 continues to be inaccurate.  Please correct the date in accordance with Item 502(b)
of Regulation S -K.

Prospectus’ Outside Front Cover Page

2. Refer to comment one in our February 6, 2014 letter.   As requested previously, delete the
phrase “until the common stock becomes quoted by a market maker on the Over -the-Counter
Bulletin Board” in the first paragraph.

Plan of Distribution, page 17

3. Refer to comment six in our February 6, 2014 letter.  We n ote the revised disclosure that the
selling stockholder “is deemed to be” an underwriter.  Please revise to state that the selling
stockholder “is” an underwriter as you disclosed on the prospectus’ outside front cover page.

Mr. Ardell Mees
ADM Endeavors, Inc.
March 25 , 2014
Page 2

Experts, page 24

4. Please revise to disclose, if true, that you are unable to obtain an Exhibit 16 letter from
Patrick Rodgers, CPA, P .A. regarding your disclosure concerning him, as indicated in our
letter to you dated March 14, 2014.  If you are able to obtain the  letter, please file the letter as
an exhibit in your next amendment.

Employment Agreements, page 35

5. In the summary compensation table you disclose that Mr. Mees’ salary for fiscal year 2013
was $54,000.  You also disclose that pursuant to the Janua ry 3, 2013 employment  agreement ,
Mr. Mees  would receive an annual salary of $72,000.  Furthermore, you disclose that in
fiscal year 2013 you paid Mr. Mees  $67,524 in officer compensation.  With a view towards
disclosure, please explain to us why there is a discrepancy among the se three different
compensation amounts, and , to the extent necessary, please revis e your disclosures
accordingly .  We note a similar discrepancy with respect to the 2012 compensation.

6. Refer to comment 12 in our letter dated February 6, 2014.  Please revise your disc losure to
indicate that Mr. Mees’ employment agreement was amended on February 6, 2014 (see
Exhibit 10.7 to the registration statement) to remove Sections 3(d), (e) , and (f) of the
agreement.  Please confirm that prior to the amendment of the employment ag reement, Mr.
Mees was not paid any bonuses or commissi ons pursuant to the application  of Sections 3(d)
through (f) of the agreement.

Consolidated Statements of Operations, page F -3

7. Please revise  to indicate that there was net income for 2013 instead of net loss.

Mr. Ardell Mees
ADM Endeavors, Inc.
March 25 , 2014
Page 3

You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Alfred P. Pavot, Jr.,
Staff Accountant , at (202) 551 -3738  if you have questions about comments on the financial
statements and related  matters.  You may contact  Edward M. Kelly, Senior Counsel,  at (202)
551-3728 or Era Anagnosti, Staff Attorney,  at (202) 55 1-3369 with any other questions.

       Very truly yours,

       /s/ Era Anagnosti

       for Pamela A. Long
       Assistant Director

cc: Via E -mail
 Diane D. Dalmy, Esq.
 2000 East 12th Avenue, Suite 32/10B
 Denver, CO 80206