SecProbe.io

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

        April 10 , 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. 3  to Registration Statement on Form S -1
  Filed April 4 , 2014
 File No. 333 -191618

Dear Mr. Mees :

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

Changes in Registrant’s Certifying Accountant, page 24

1. You disclose that “Other than an explanatory paragraph included in Rodgers’ audit report for
the Company's fiscal years ended December 31, 2012 and 2011 relating to the uncertainty of
the Company's ability to continue as a going concern, the audit report of Rodgers on the
company's financ ial statements for the fiscal years ended December 31, 2012 and 2011 and
through January 22, 2014, did not contain an adverse opinion or a disclaimer of opinion, nor
was it qualified or modified as to uncertainty, audit scope or accounting principles.”  We
note, however, that no such explanatory paragraph was included in Rodgers’ audit reports for
those periods in any of the prior filings. Please revise to remove the qualifying language from
the beginning portion of this sentence.

Financi al Statements

2. Please place your financial statements inside of the prospectus rather than at the back of the
registration statement.

Report of Independent Registered Public Accounting Firm, page F -1

3. We note your disclosure under the going concern heading on page 28.  Given your significant
working capital deficit, it is unclear why the audit report does not include a going concern

Mr. Ardell Mees
ADM Endeavors, Inc.
April 10 , 2014
Page 2

 paragraph consistent with the guidance in AU Section 341.  Please explain to us the factors
that your auditor considered in assessing the ne ed for a going concern paragraph.

Exhibit 5.1

4. Please have counsel revise the first paragraph of the opinion to refer to ADM Endeavors, Inc.
as the registrant and to reflect the registration statement’s correct filing date, October 8,
2013.

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