SecProbe.io

Mail Stop 4631

October 2, 2017

Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 N. 3rd Str.
Bismarck, ND 58501

Re: ADM Endeavors, Inc.
  Registration Statement on Form S-1
Filed  September 14, 2017
  File No.  333-220452

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 .  If you do not believe our com ments 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, w e may have  additional comments.

General

1. We note that you were delinquent filing your periodic reports beginning with your report
for the quarter ended March 31, 2015.  The failure to file a required SEC report on time
constitutes a violation of Section  13(a) of the Exchange Act and may result in revocation
of your registration under the Exchange Act.  Please include appropriate risk factor
disclosure regarding your inability to file timely reports and the risk you face by not
adhering to required SEC re porting requirements.

2. You have an outstanding registration statement, on Form S -1 (333 -201351), that registers
some of the same securities you are registering in this filing.  If you intend to use a
combined prospectus under Securities Act Rule 429 for bo th filings, please update this
filing accordingly.  Please refer to Securities Act Rule 429.

Ardell Mees
ADM Endeavors, Inc.
October 2, 2017
Page 2

 Common Stock and Preferred Stock Outstanding and Related Stockholder Matters, page 5

3. We note your disclosure that “[a]s of the date hereof” 127,607,169 shares of  common
stock were issued and outstanding.  We also note, here and throughout the filing, that
128,182,497 shares of common stock were issued and outstanding as of August 23, 2017.
Please revise accordingly.

Recent Sales of Unregistered Securities, page 55

4. We note your disclosure on page 15 that you issued 2,250,000 shares to Calving Mees  on
May 30, 2017.  We also note that previously reported sales of unregistered securities
were not included in your disclosure.  Please revise to include all unregistered sales of
securities within the past three years, including any shares issued as compe nsation in lieu
of salary or for services rendered.  Please refer to Item 701 of Regulation S -K.  In
addition, please revise the list of selling security holders on page 16 accordingly.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  accel eration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Please contact  Sergio Chinos, Staff Attorney , at (202) 551 -7844  or me at (202) 551 -3397
with any other questions.

Sincerely,

 /s/ Jay Ingram

Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction

cc: Chase Chandler, Esq.