SecProbe.io

April 9, 2015

Via E -mail
Nate Engel
Chief Executive Officer
International Endeavors Corporation
43020 Blackdeer Loop
Temecula, California 92590

Re: International Endeavors Corporation
Registration Statement on Form S -1
Filed March 10, 2015
  File No. 333 -202639

Dear Mr. Engel :

We have reviewed your registration statement  and have the following 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 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 supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you , or anyone authorized to do so on your
behalf , present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

2. We note that the company’s business is primarily that of acquiring and holding for
investment real estate .  Please file your next amendment on Form S -11 as required by
General Instruction A to Form S -11.

Nate Engel
International Endeavors Corporation
April 9, 2015
Page 2

 Risk Factors, page 8

3. Pleas e add a risk factor that address es the risk related to your net losses , including  your
auditor ’s opinion that there is substantial doubt about your ability to continue as a going
concern.

4. We note your disclosure on page 6 that you may conduct an offering of your shares in the
future. Please add risk factor disclosure regarding the potential for dilution in the event
this occur s.

As there is no public market , page 10

5. Please revise your disclosure to clarify that you will seek to be quoted on the OTC -BB.
Please make similar revision s on page s 12 and 14 .

Description of Business, page 17

6. Please provide us with support for all quantitative and qualitative business and industry
data.   For example  only, we note your disclosure on page 18 regarding the  project ed costs
for development,  estimated grape yield per acre, cost of bottle production, and profit
potential.  Clearly mark the specific language in the supporting materials that supports
each statement.   The requested information should be filed as EDGAR correspondence
or, alternatively, should be sent in paper form accompanied b y a cover letter indicating
that the material is being provided pursuant to Securities Act Rule 418 and that such
material should be returned to the registrant upon completion of the staff review process .

7. We note you currently own 10 acres of land.  Please  clarify the acreage devoted to your
RV operations and the amount that will be devoted to a vineyard.

8. We note your disclosure on page 17 that you plan to lease your 10 RV sites on a monthly
basis. Please clarify whether you will only lease sites on a mo nthly basis or whether you
may lease sites on a weekly basis  or yearly basis  and, if so, disclose  whether the rental
price would vary in those instances .

Special Note Regarding Forward -Looking Statements, page 21

9. Please revise your disclosure in the last paragraph hereunder to clarify that the prospectus
will be updated to the extent required by law .

Executive Compensation, page 22

10. Please  revise your table in accordance with Item 402(n) of Regulation S -K.

Nate Engel
International Endeavors Corporation
April 9, 2015
Page 3

Note 1 – Summary of Significant Accounting Policies , page F -6

Revenue Recognition

11. Please expand your disclosures to discuss your accounting policy for customer leases
similar to what i s within your critical accounting policy for revenue recognition on page
27.   However, please also clarify what is meant by nonrefundable payments (after 10
days) and expand to also discuss the typical duration of your lease agreements.   To the
extent pa yments are refundable within the first 10 days please clarify your basis for full
recognition upon receipt versus until the lapse of the refundable period.

Capital Expenditures

12. Please tell us and expand your disclosures to discuss your accounting policy for land
improvements.   Your discussion should include the types of costs that are capitalized and
the periods in which they are capitalized.

Management ’s Discussion and Analysis of Financial Condition and Results of Operations, page
26

13. Please revise your business or MD&A section to describe the company’s plan of
operation for the remainder of the fiscal year as require d by Item 101(a)(2) of Regulation
S-K.  Provide details of your specific plan of operation, including detailed milestones, the
anticipated time frame for beginning and completing each milestone, categories of
expenditures and the expected sources of such f unding.  Please explain how the company
intends to meet each of the milestones if it cannot receive funding.

Exhibit s

14. We note that you have filed Exhibit s 3 and 3.1 as jpeg images.  Please note that while it is
appropriate to file electronic documents with images in them, it is not appropriate to file
an entire docu ment as an image.  Refer to Rule 102(a) of Regulation S -T and Section 2.1
of Volume II of the EDGAR Filer Manual.  Please re -file the applicable exhibits in one of
the correct document formats .

Signatures

15. Please include the signature of your principal financial  officer.  See Instruction 1 to the
Signatures on Form S -1.

Nate Engel
International Endeavors Corporation
April 9, 2015
Page 4

 We urge all persons who are res ponsible 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 regist ration 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 e ffective, it does 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 responsibility 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 feder al
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 acceleration 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 state ment.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Peter McPhun, Staff Accountant,  at (202) 551 -3581  or Wilson Lee,
Senior Staff Accountant,  at (202) 5 51-3468  if you have questions regarding comments on the
financial statements and related matters.  Please contact Rahul Patel, Staff Attorney,  at (202)
551-3799  or me at (202) 551 -3233  with any other questions.

Sincerely,

 /s/ Tom Kluck

Tom Kluck
Legal Branch Chief