SecProbe.io

January 23, 2015

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

Re: ADM Endeavors, Inc.
  Registration Statement on Form S-1
Filed  January 2, 2015
  File No.  333-201351

Dear Mr. Mees :

We have limited our review of your registration statement to those issues we have
addressed in our 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 amending your registration statement and providing the
requested information .  Where 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 any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

General

1. Please update your registration statement to reflect your current and future operations.  For
example, on page 27 you have a target date of September 1, 2014 for your planned district
office in Kansas City, MO .

Risk Factors, page 9

Risks Related to The Offering, page 13

We are not a fully reporting company under the Exchange Act of 1934 …, page 14

2. We note that on April 28, 2014  you filed a Form 8 -A registering common stock under
Section 12(g)  of the Securities Exchange Act of 1934 .  Therefore,  your risk factor on page 14

Ardell Mees
ADM Endeavors, Inc.
January 23, 2015
Page 2

 does not appear to be accurate.  Please remove this risk factor, or clarify the nature of the risk
you are trying to describe.

Selling Security Holders, page 16

3. Please describe how the selling security holders acquired the securities they may offer and
sell pursuant to the registration statement, including the da tes of the transactions and the
consideration paid by  the selling security holders.

4. Please identify by name the natural person(s) who exercise voting or investment control or
both with respect to the shares held by any of the selling security holders that are not natural
persons. For guidance, please refer to Question 140.02 of the Regulation S -K Compliance
and Disclosure Interpretations.

5. Please disclose any position, office, or other material relationship that any selling security
holder has had within the past three years with you or any of your predecessors or affiliates.
Refer to Item 507 of Regulation S -K.

6. Please tell us whether any of the selling s ecurity holders is a broker -dealer or a n affiliate of a
broker -dealer.  For any selling s ecurity holder who is a broker -dealer, the prospectus should
state that the selling s ecurity holder  is an underwriter.  For any selling security holder who is
an affiliate of a broker -dealer, the prospectus should state that the selling security holder
purchased the securities in the ordinary course of business and at the time of the purchase of
the securities to be resold ha d no agreements or understandings, directly or indirectly, with
any perso n to distribute the securities.  If a selling security holder  is unable to provide these
representations, then the prospectus should state that the selling security holder is an
under writer.  Note that broker -dealers and their affiliates who received their securities as
compensation for underwriting activities need not be identified as underwriters.

Executive Compensation, page 31

7. Please revise this section to include Item 402 of Reg ulation S -K disclosure for the fiscal year
ended December 31, 2014. For guidance, refer to Question 117.05 of the Regulation S -K
Compliance and Disclosure Interpretations.

Management’s Discussion and Analysis of Financial Condition and Results of Operatio ns, page
27

8. Please provide management’s discussion and analysis of your financial condition and results
of operations for interim period financial statements. See Item 303(b) of Regulation S -K.

Ardell Mees
ADM Endeavors, Inc.
January 23, 2015
Page 3

 Exhibits, page 56

Exhibit 23.1

9. Please revise your audit or’s consent so that it references the appropriate date and file number
for this registration statement.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it d oes not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsib ility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting ac celeration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Ardell Mees
ADM Endeavors, Inc.
January 23, 2015
Page 4

 Please contact Asia Timmons -Pierce, Staff Attorney,  at (202) 551 -3754  or me at (202)
551-3765 with any other questions.

Sincerely,

 /s/ Pamela Long

 Pamela Long
Assistant Director

cc: Chase Chandler
      Brunson Chandler & Jones, PLLC