SecProbe.io

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 August 21, 2025

Wah Fu
Chief Executive Officer
International Endeavors Corporation
Unit 2, Level 6
Westin Centre
26 Hung To Road
Kwun Tong, Hong Kong

 Re: International Endeavors Corporation
 Amendment No. 2 to Registration Statement on Form 10-12G
 Filed August 12, 2025
 File No. 000-55649
Dear Wah Fu:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments. Unless we note otherwise, any
references to prior
comments are to comments in our July 29, 2025 letter.

Amendment No. 2 to Registration Statement on Form 10-12G filed August 12, 2025
Executive Compensation, page 60

1. We note the revisions made in response to prior comment 8 and we
reissue. We note
 the disclosure on page 58 regarding base salaries and the disclosure on
page 59 that
 you have agreed to pay Messrs. Fu and Au-Yeung a monthly fee of
HK$20,000
 (approximately $2,564) and HK$10,000 (approximately $1,282) for their
services as
 directors. However, the summary compensation table does not to reflect
any base
 salaries. Please reconcile. In addition, the compensation paid for
services as directors
 does not appear to reflect the full payment for the year ended December
31, 2024, and
 only appears to reflect two months. Please revise to provide the
information required
 by Item 402 of Regulation S-K or advise. In this regard, this would also
include
 compensation paid as officers and directors of Modulink, the
predecessor.
 August 21, 2025
Page 2

Index to Consolidated Financial Statements, page F-1

2. We note your response to prior comment 12. Please address the following:
 We note your determination that MIL is the accounting acquirer and
ongoing
 operating business, and thus the predecessor for financial reporting
 purposes. Please provide us with your significance assessment for the
acquisition
 of IDVV and your analysis of whether you are required to file separate
historical
 financial statements of IDVV and pro forma information required by
Rule 8-
 04 and 8-05 of Regulation S-X, respectively; and
 Please clarify how the assets and liabilities of IDVV were initially
recognized by
 ModuLink Inc. given that the Stock Purchase Agreement dated January
22, 2025
 and consummated February 10, 2025 involved entities that were not
under
 common control. Please reference the authoritative accounting
literature
 management relied upon.
3. We also note you accounted for the Share Exchange as a transaction
between entities
 under common control and that the historical financial statements of the
registrant
 reflect those of MIL for all periods, which are presented with a
retrospective
 presentation and combination of the consolidated financial statements as
if the Share
 Exchange and disposal of the original business had occurred and the
current group
 structure had existed at the beginning of the earliest reporting period
presented. We
 further note that it appears that IDVV and MIL were not under the common
control of
 Mr. Tam, Mr. Fu and Mr. Au-Yeung ( control group ) until February
10, 2025.
 Please address the following:
 Please tell us your basis in U.S. GAAP for excluding the original
business of
 IDVV from the historical consolidated financial statements that
include IDVV.
 Please clarify for us who controlled MIL for all periods from
January 1, 2023 to
 date. In your response, please clarify for us if ownership of MIL
changed since
 January 1, 2023
 Please tell us your basis in U.S. GAAP for consolidating IDVV and
MIL prior to
 February 10, 2025, the date it appears these entities became under
common
 control of the control group.
4. Notwithstanding the comments above, we note your view that IDVV (the
registrant)
 qualified as a shell company prior to the acquisition, which appears
contrary to
 information included in its December 31, 2024 annual report and March
31, 2025
 quarterly report respectively published February 7, 2025 and April 28,
2025 on the
 OTC Markets website. Under the Shell Status section, both reports
indicate the
 company was not a shell company and that its shell status had not
changed since the
 previous reporting period. Additionally, the financial statements and
related disclosure
 in both reports portray the company as actively operating. Lastly, we
note that two
 promissory notes of IDVV were transferred pursuant to the Stock Purchase
 Agreement dated January 22, 2025. Please further explain how you
determined it
 appropriate to omit separate financial statements of IDVV considering
these facts.
 August 21, 2025
Page 3
Exhibits

5. We note the response to prior comment 10 that you have an oral
agreement, but no
 written agreement, with Leidenford Ltd. Please file a written
description of the oral
 agreement. See Regulation S-K C&DI Question 146.04.

 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.

 Please contact Frank Knapp at 202-551-3805 or Isaac Esquivel at
202-551-3395 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Benjamin Holt at 202-551-6614 or Pam Howell at 202-551-3357 with
any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Jenny Chen-Drake
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