SEC Company Response from ADM ENDEAVORS, INC. (ADMQ) (CIK 0001588014) (ADMQ) — Dec 20, 2017
ADM ENDEAVORS, INC. (ADMQ) (CIK 0001588014)
Date: Dec. 20, 2017 · CIK: 0001588014 · Accession: 0001493152-17-014878
AI Filing Summary & Sentiment
File numbers found in text: 333-220452
Referenced dates: November 20, 2017
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CORRESP
1
filename1.htm
December
19, 2017
Attn:
Jay Ingram, Legal Branch Chief
Office
of Manufacturing and Construction
United
States Securities and Exchange Commission
Division
of Corporation Finance
100
F Street, N.E.
Washington,
DC 20549
Re:
ADM
Endeavors, Inc.
Amendment
No 1 to Registration Statement on Form S-1
Filed
November 13, 2017
File
No. 333-220452
Ladies
and Gentlemen:
ADM
Endeavors, Inc. (the “ADM Endeavors” or the “Company”) provides the following response (the “Response
Letter”) to the comments contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation
Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) dated November
20, 2017, relating to the above-referenced filing.
In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:
Recent
Sales of Unregistered Securities, page 55
1.
We
note your response to prior comment 4 and reissue our comment. We also note the sale of unregistered securities disclosed
in previously filed quarterly reports. For example:
●
During
the second quarter of 2015 you issued 5,375,000 and 2,225,000 shares for consulting services.
●
On
May 30, 2016, you issued 2,250,000 shares for consulting services.
●
On
July 26, 2016, you issued 350,000 shares for consulting services.
●
On
May 30, 2017, you issued 2,250,000 shares for consulting services.
●
On
June 30, 2017, you issued “approximately 187,500” shares.
Please
revise to include all unregistered sales of securities within the past three years, including any shares issued as compensation
on 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.
Response:
We have revised the unregistered sales of equity securities section to list all unregistered sales of securities within the past
three years. We have also updated the list of selling security holders on page 16, accordingly.
Thank
you for your assistance and review.
Sincerely,
ADM
Endeavors, Inc.
/s/
Ardell Mees
Ardell
Mees
Chief
Executive Officer