SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 January
29, 2026

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
DC 20549

 Re:
 ADM
 Endeavors, Inc.
 Registration
 Statement on Form S-1
 File
 No. 333-292924

 Ladies
and Gentlemen:

 The
undersigned registrant (the "Registrant") hereby requests that the Securities and Exchange Commission (the "Commission")
take appropriate action to cause the above-referenced Registration Statement on Form S-1 to become effective on Monday, February 2, 2026,
at 4:30 p.m. ET, or as soon thereafter as is practicable.

 The
Registrant authorizes Lance Brunson of Brunson Chandler & Jones, PLLC, outside counsel to the Registrant, to verbally alter the requested
date and time of effectiveness of the Registration Statement with the Commission. Please call Mr. Brunson at (801) 303-5737 with any
questions you may have.

 Thank
you for your assistance.

 Sincerely,

 ADM
Endeavors, Inc.

 /s/
Marc Johnson

 Marc
Johnson

 Chief
Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 28, 2026

Marc Johnson
Principal Executive Officer
ADM Endeavors, Inc.
5941 Posey Lane
Haltom City, TX 76117

 Re: ADM Endeavors, Inc.
 Registration Statement on Form S-1
 Filed January 23, 2026
 File No. 333-292924
Dear Marc Johnson:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Scott Anderegg at 202-551-3342 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Chase Chandler
</TEXT>
</DOCUMENT>

August 2, 2019
Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 N 3rd St
Bismarck, ND 58501
Re:ADM Endeavors, Inc.
Amendment No. 3 to Registration Statement on Form 10-12G
Filed July 26, 2019
File No. 000-56047
Dear Mr. Mees:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

ADM
Endeavors, Inc.

2021
N. 3rd Street Bismarck, N.D. 58501 * (701) 224-9338

July
26, 2019

Via
Edgar Only

Kate
McHale

Staff
Attorney

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

Washington,
D.C. 20549

    RE:
    ADM Endeavors, Inc.

    Form 10-12G/A - Amendment No. 2

    Filed July 8, 2019

    File No. 000-56047

Dear
Ms. McHale:

ADM
Endeavors, Inc. (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 July 25, 2019, relating to the above-referenced
filing.

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

Form
10-12G/A Filed July 8, 2019

Item
2 – Financial Information, page 7

    1.

    Please expand your
    disclosure of financial information in Item 2 to include material changes in results of operations and financial condition
    for the interim period ended March 31, 2019. Refer to Item 303(b) of Regulation S-K for guidance.

Response:
We have added in Item 2 the excerpt from the Company’s Form 10-Q for the period ended March 31, 2019 from Item 2., Management’s
Discussion and Analysis of Financial Condition or Plan of Operation.

Thank
you for your assistance and review.

Sincerely,

/s/
Ardell Mees

Ardell
Mees

Chief
Executive Officer

July 25, 2019
Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 N 3rd St
Bismarck, ND 58501
Re:ADM Endeavors, Inc.
Amendment No. 2 to Registration Statement on Form 10-12G
Filed July 8, 2019
File No. 000-56-047
Dear Mr. Mees:
            We have reviewed your filing 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 these comments 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 our
comments apply 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 these
comments, we may have additional comments.
Form 10-12G/A2 Filed July 8, 2019
Item 2- Financial Information, page 7
1.Please expand your disclosure of financial information in Item 2 to include material
changes in results of operations and financial condition for the interim period ended
March 31, 2019. Refer to Item 303(b) of Regulation S-K for guidance.
            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.

 FirstName LastNameArdell Mees
 Comapany NameADM Endeavors, Inc.
 July 25, 2019 Page 2
 FirstName LastName
Ardell Mees
ADM Endeavors, Inc.
July 25, 2019
Page 2
             You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744 or Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355 if you have questions regarding the
comment on the financial statements and related matters.  Please contact Kate McHale, Staff
Attorney, at (202) 551-3464 or Jay Ingram, Legal Branch Chief, at (202) 551-3397 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

ADM
Endeavors, Inc.

2021
N. 3rd Street Bismarck, N.D. 58501 * (701) 224-9338

July
8, 2019

Via
Edgar Only

Kate
McHale

Staff
Attorney

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

Washington,
D.C. 20549

    RE:
    ADM
    Endeavors, Inc.

    Form
    10-12G/A - Amendment No. 1

    Filed
    June 21, 2019

    File
    No. 000-56047

Dear
Ms. McHale:

ADM
Endeavors, Inc. (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 July 2, 2019, relating to the above-referenced
filing.

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

Form
10-12G/A Filed June 21, 2019

Critical
Accounting Policies and Estimates

Derivative
Instruments, page 9

    1.

    We
    have read your response to prior comment 6. Please further expand your disclosure to include the maturity date of the liability
    and the interest rate on the loan. Financial Statements, page F-1

Response:
We have modified in the Financial Statements for the period ended December 31, 2019 for Derivative Instruments as follows:

Derivative
Instruments

The
conversion features embedded in the convertible notes were evaluated to determine if such conversion feature should be bifurcated
from its host instrument and accounted for as a freestanding derivative. In the convertible notes with variable conversion terms,
the conversion feature was accounted for as a derivative liability. The derivatives associated with the term convertible notes
wert recognized as a discount to the debt instrument and the discount is amortized over the expected life of the notes with any
excess of the derivative value over the note payable value recognized as additional interest expense at the issuance date.

The
derivative liability was calculated using the Black-Scholes method over the expected terms of the convertible debt, with a risk-free
rate of 2.45% and volatility of 100% as of December 31, 2018.

The
note is convertible into common stock at a price of 35% of the lowest three trading prices during the ten days prior to conversion.

The convertible note originally
matured in March 2019 and was extended to March 2020. The note had fees of approximately $53,000 which were amortized
through March 2019 resulting in an effective interest rate of approximately 50%.

ADM
Endeavors, Inc.

2021
N. 3rd Street Bismarck, N.D. 58501 * (701) 224-9338

    2.

    Please
    update your financial statements for the interim period ended March 31, 2019 in accordance with Rule 8-08 of Regulation S-X.

Response:
We have included the interim period ended March 31, 2019, as requested.

Thank
you for your assistance and review.

Sincerely,

/s/
Ardell Mees

Ardell
Mees

Chief
Executive Officer

July 2, 2019
Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 N 3rd St
Bismarck, ND 58501
Re:ADM Endeavors, Inc.
Registration Statement on Form 10-12G
Filed April 30, 2019
File No. 000-56-047
Dear Mr. Mees:
            We have reviewed your filing 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 these comments 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 our
comments apply 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 these
comments, we may have additional comments.
Form 10-12G/A Filed June 21, 2019
Critical Accounting Policies and Estimates
Derivative Instruments, page 9
1.We have read your response to prior comment 6.  Please further expand your disclosure to
include the maturity date of the liability and the interest rate on the loan.
Financial Statements, page F-1
2.Please update your financial statements for the interim period ended March 31, 2019 in
accordance with Rule 8-08 of Regulation S-X.
            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.

 FirstName LastNameArdell Mees
 Comapany NameADM Endeavors, Inc.
 July 2, 2019 Page 2
 FirstName LastName
Ardell Mees
ADM Endeavors, Inc.
July 2, 2019
Page 2
            You may contact Tracie Mariner at 202-551-3744 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Kate McHale at 202-551-3464 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

June
21, 2019

Via
Edgar Only

Kate
McHale

Staff
Attorney

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

Washington,
D.C. 20549

    RE:
    ADM
    Endeavors, Inc.

    Form
    10-12G

    Filed
    April 30, 2019

    File
    No. 000-56047

Dear
Ms. McHale:

ADM
Endeavors, Inc. (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 May 29, 2019, relating to the above-referenced
filing.

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

Form
10-12G Filed April 30, 2019

Item
1. Business, page 4

    1.
    In
    note 10 of your financial statements, you disclose one customer accounted for 15% of your revenue. Please identify this customer
    and disclose your reliance in this section.

Response:
This response is applicable for your Comment 1 and Comment 10.

TBNR,
LLC accounted for more than 15% and 14% of our (Just Right Products, Inc.) revenue for the years ended December 31, 2018 and 2017,
respectively.

We
have modified our disclosure in Item 1 of the Form 10-12G as follows:

TBNR,
LLC, a primary customer of Just Right Products, accounted for more than 15% of our revenue for the year ended December 31, 2018.

    2.
    Please
    elaborate on the business of ADM Enterprises. For example, we note you have disclosed a franchise agreement in the notes to
    your financial statements. In addition, you state you provide “customized construction and installation of grocery store
    decor” but you do not appear to have the infrastructure to carry out this business. Please give investors a better sense
    of the development of this business.

Response:
ADM Enterprises, LLC does not have a franchise agreement whereas Just Right Products, Inc. does have a franchise agreement, as
disclosed. ADM Enterprises, LLC has provided the custom installation of grocery store décor for the last 28 years and will
expand its services upon the next layer of financing. Just Right Products, Inc. will expand its production facilities upon the
next layer of financing.

We
have modified our Item 1 in the Form 10-12G as follows:

Just
Right Products

Just
Right Products has a franchise agreement effective February 19, 2014 expiring in February 2024, with a right to renew for an additional
5 years to operate stores and websites in the Company’s exclusive territory. The Company is obligated to pay 5% of gross
revenue for use of systems and manuals.

Just
Right Products is seeking additional financing to expand to other regional cities accordingly.

ADM
Enterprises

ADM
Enterprises is seeking additional financing in order to facilitate its planned growth and execute our business plan in this filing
and prior filings.

We
have modified our Note 13 in the Form 10-12G as follows:

NOTE
3 – COMMITMENTS AND CONTINGENCIES

Franchise
Agreement

Just
Right Products, Inc. has a franchise agreement effective February 19, 2014 expiring in February 2024, with a right to renew for
an additional 5 years to operate stores and websites in the Company’s exclusive territory. The Company is obligated to pay
5% of gross revenue for use of systems and manuals.

During
the years ended December 31, 2018 and 2017, the Company paid $57,446 and $62,030 for the franchise agreement.

Employees,
page 6

    3.
    Please
    disclose the number of total employees and full time employees for your two business segments. See Item 101(h)(4)(xii) of
    Regulation S-K.

Response:
Just Right Products, Inc. has 28 full time employees and 4 part time employees. ADM Enterprises, LLC has 1 full time employee
and 1 part time employee.

The
Company has revised its Form 10-12G as follows:

Just
Right Products, Inc. has 28 full time employees and 4 part time employees. ADM Enterprises, LLC has 1 full time employee and 1
part time employee. The Company has employment agreements with its chief executive officer / chief financial officer and its chief
operating officer. On April 19, 2018, the Company executed two-year employment agreements, respectively, with Ardell D. Mees,
the Company’s Chief Executive Officer and Chief Financial Officer, and Marc Johnson, the Company’s Chief Operating
Officer. As compensation for services, Mr. Mees and Mr. Johnson are to receive annual base salaries of $60,000 each.

Liquidity
and Capital Resources, page 8

    4.
    Please
    expand your disclosure to include your estimated cash requirements over the next twelve months.

Response:
We have historically met our cash needs through a combination of cash flows from operating activities and proceeds from loans,
credit cards and financing by our officers and directors. Our cash requirements are generally for selling, general and administrative
activities. We believe that our cash balance is not sufficient to finance expansion, capital improvements and repayment of non-operating
liabilities including officer compensation through the next 12 months. To meet our expansion and capital improvements requirements
and satisfy liabilities, we believe we need an additional $1,000,000 for the next 12 months.

The
Company has modified its Form 10-12G as follows:

At
December 31, 2018, we had cash of $31,199. We have historically met our cash needs through a combination of cash flows from operating
activities and proceeds from loans, credit cards and financing by our officers and directors. Our cash requirements are generally
for selling, general and administrative activities. We believe that our cash balance is not sufficient to finance expansion, capital
improvements and repayment of non-operating liabilities including officer compensation through the next 12 months. To meet our
expansion and capital improvements requirements and satisfy liabilities, we believe we need an additional $1,000,000 for the next
12 months.

    5.
    Please
    expand your disclosure on page 9 to provide a quantitative and qualitative explanation of the reasons for material changes
    in your working capital items from the prior year.

Response:
As of December 31, 2018, current liabilities exceeded current assets by $622,302. Current assets increased from $354,672 at December
31, 2017 to $380,657 at December 31, 2018, whereas current liabilities increased from $284,194 at December 31, 2017 to $1,002,959
at December 31, 2018. The increase in current liabilities is due to the following: derivative liability of $197,572 and $-, accrued
expenses for compensation of $216,250 and $-, convertible debt $89,544 and $-, and credit card payables from $197,153 and $94,288
as of December 31, 2018 and 2017, respectively. The Company has modified its filing to as follows:

As
of December 31, 2018, current liabilities exceeded current assets by $622,302. Current assets increased from $354,672 at December
31, 2017 to $380,657 at December 31, 2018, whereas current liabilities increased from $284,194 at December 31, 2017 to $1,002,959
at December 31, 2018. The increase in current liabilities is due to the reverse merger on April 1, 2018, the derivative liability
for a convertible note payable, and the increase of accrued expenses associated with the liabilities and/or obligations assumed
post-reverse merger.

    6.
    Please
    expand your disclosure to identify and describe the derivative liability and its terms in the amount of $197,572 on your balance
    sheet as of December 31, 2018. Refer to Item 303(a)(1) of Regulation S-K and FRC Section 501.03.a for guidance.

Response:
We have modified our disclosures on page 9 as follows:

Derivative
Instruments

The
conversion features embedded in the convertible notes were evaluated to determine if such conversion feature should be bifurcated
from its host instrument and accounted for as a freestanding derivative. In the convertible notes with variable conversion terms,
the conversion feature was accounted for as a derivative liability. The derivatives associated with the term convertible notes
wert recognized as a discount to the debt instrument and the discount is amortized over the expected life of the notes with any
excess of the derivative value over the note payable value recognized as additional interest expense at the issuance date.

The
derivative liability was calculated using the Black-Scholes method over the expected terms of the convertible debt, with a risk-free
rate of 2.45% and volatility of 100% as of December 31, 2018.

The
note is convertible into common stock at a price of 35% of the lowest three trading prices during the ten days prior to conversion.

Revenue, page 11

    7.
    Please expand your disclosure to include the percentage of revenue earned from grocery store decor design and from promotional products for each year presented or provide similar disclosure that clarifies the magnitude of revenue earned from each of your principal product types.

Response:
The Company contacted the accountant listed on the comment letter as it could not be determined where this disclosure was deficient.
It was agreed that the belief this comment was related to page 8 and the respective revenue discussion. Therefore, the Company
has modified its prior filing as follows:

COMPARISON
OF THE YEAR ENDED DECEMBER 31, 2018 TO THE YEAR ENDED DECEMBER 31, 2017

Results
of Operations

Revenue

For
the year ended December 31, 2018, the Company had revenues of $3,617,771 compared to $3,240,005 for the same period in 2017. The
increase in revenue of $377,766, or 11.66%, is primarily due to marketing programs with area schools. The revenue associated with
Just Right Products and ADM Enterprises for 2018 were $3,564,295 (98.5%) and $53,476 (1.5%), respectively.

Item
5. Directors and Executive Officers, page 12

    8.
    You
    state in the first paragraph “[t]here are no family relationships among our directors, executive officers, director
    nominees”; however, you disclose on page 14 Ardell Mees and Tammera Mees are married. Please reconcile this disclosure.

Response:
As of December 31, 2018, there are no family relationships as Tammera Mees resigned from her positions on April 19, 2018. The
Company modified the disclosure as follows:

The
following table sets forth the names and ages of our current directors and executive officers. Also, the principal offices and
positions with us held by each person and the date such person became our director, executive officer. Our executive officers
are appointed by our Board of Directors. Our directors serve until the earlier occurrence of the election of his or her successor
at the next meeting of stockholders, death, resignation or removal by the Board of Directors. As of December 31, 2018, there are
no family relationships among our directors, executive officers, director nominees. Prior to April 17, 2018, Ardell Mees and Tammera
Mees, which are married, served as officers and directors.

Additionally,
it was noted that the Summary Compensation Table on page 15 had incorrect dates for footnotes 1 and 2 of the table. The year of
resignation and appointment was 2018, not 2017, and has been corrected accordingly.

Item
10. Recent Sales of Unregistered Securities, page 17

    9.
    You
    disclose you have not had recent sales of securities but we also note you have issued securities to Mr. Johnson within the
    three year period. Please disclose these shares and all other transactions required under Item 701 of Regulation S-K.

Response:

The
Company has not sold any securities to any party, including Mr. Johnson. The Company did issue 2,000,000 shares of restricted
Series A preferred stock to Marc Johnson in conjunction to the acquisition of Just Right Products, Inc. The Company has modified
its filing as follows:

On
April 19, 2018, the Company issued 2,000,000 shares of restricted Series A preferred stock to Marc Johnson in conjunction to the
acquisition of Just Right Products, Inc. There was no cash or cash equivalents used in this transaction.

Financial Statements Note 10- Concentration of Customer,
page F-13

    10.
    We note your disclosure stating that, for the years ended December 31, 2018 and 2017, one customer made up 15% and 14%, respectively of your revenues. Please expand your disclosure to include the customer name. Refer to the guidance in Item 101(c)(vii) of Regulation S-K.

Response:

Our
response to this comment, which is very similar to comment #1, is the identical response, which is as follows:

TBNR,
LLC accounted for more than 15% and 14% of our (Just Right Products, Inc.) revenue for the years ended December 31, 2018 and 2017,
respectively. We have modified our disclosure in Note 10 of the Form 10-12G as follows:

NOTE
10 – CONCENTRATION OF CUSTOMER

For
the years ended December 31, 2018 and 2017, one customer, TBNR, LLC, made up 15% and 14% of revenues, respectively. No customers
accounted for more than 10% of accounts receivable as of December 31, 2018 and 2017, respectively.

Thank
you for your assistance and review.

    Sincerely,

    /s/
    Ardell Mees

    Ardell
    Mees

    Chief
    Executive Officer

May 29, 2019
Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 N 3rd St
Bismarck, ND 58501
Re:ADM Endeavors, Inc.
Registration Statement on Form 10-12G
Filed April 30, 2019
File No. 000-56-047
Dear Mr. Mees:
            We have reviewed your filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-12G Filed April 30, 2019
Item 1. Business , page 4
1.In note 10 of your financial statements, you disclose one customer accounted for 15% of
your revenue.  Please identify this customer and disclose your reliance in this section.
2.Please elaborate on the business of ADM Enterprises.  For example, we note you have
disclosed a franchise agreement in the notes to your financial statements.  In addition, you
state you provide "customized construction and installation of grocery store decor" but
you do not appear to have the infrastructure to carry out this business.  Please give
investors a better sense of the development of this business.

Employees, page 6

 FirstName LastNameArdell Mees
 Comapany NameADM Endeavors, Inc.
 May 29, 2019 Page 2
 FirstName LastNameArdell Mees
ADM Endeavors, Inc.
May 29, 2019
Page 2
3.Please disclose the number of total employees and full time employees for your two
business segments.  See Item 101(h)(4)(xii) of Regulation S-K.
Liquidity and Capital Resources, page 8
4.Please expand your disclosure to include your estimated cash requirements over the next
twelve months.
5.Please expand your disclosure on page 9 to provide a quantitative and qualitative
explanation of the reasons for material changes in your working capital items from the
prior year.
6.Please expand your disclosure to identify and describe the derivative liability and its
terms in the amount of $197,572 on your balance sheet as of December 31, 2018.  Refer
to Item 303(a)(1) of Regulation S-K and FRC Section 501.03.a for guidance.
Revenue, page 11
7.Please expand your disclosure to include the percentage of revenue earned from grocery
store decor design and from promotional products for each year presented or provide
similar disclosure that clarifies the magnitude of revenue earned from each of your
principal product types.
Item 5. Directors and Executive Officers, page 12
8.You state in the first paragraph "[t]here are no family relationships among our directors,
executive officers, director nominees"; however, you disclose on page 14 Ardell Mees and
Tammera Mees are married.  Please reconcile this disclosure.
Item 10. Recent Sales of Unregistered Securities, page 17
9.You disclose you have not had recent sales of securities but we also note you have issued
securities to Mr. Johnson within the three year period.  Please disclose these shares and all
other transactions required under Item 701 of Regulation S-K.
Financial Statements
Note 10- Concentration of Customer, page F-13
10.We note your disclosure stating that, for the years ended December 31, 2018 and 2017,
one customer made up 15% and 14%, respectively of your revenues.  Please expand your
disclosure to include the customer name.  Refer to the guidance in Item 101(c)(vii) of
Regulation S-K.
            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.

 FirstName LastNameArdell Mees
 Comapany NameADM Endeavors, Inc.
 May 29, 2019 Page 3
 FirstName LastName
Ardell Mees
ADM Endeavors, Inc.
May 29, 2019
Page 3
            You may contact Tracie Mariner, Staff Accountant, at (202)551-3744 or Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355 if you have questions regarding comments
on the financial statements and related matters.  Please contact Kate McHale, Staff Attorney, at
(202) 551-3464 or Jay Ingram, Legal Branch Chief, at (202) 551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

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ADM
Endeavors, Inc.

2021
N. 3rd Street

Bismarck,
ND 58501

January
8, 2018

United
States Securities and Exchange Commission

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.

    Registration
    Statement on Form S-1/A

    File
    No. 333-220452

Ladies
and Gentlemen:

The
undersigned registrant (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”)
take appropriate action to cause the above-referenced Registration Statement on Form S-1/A to become effective on January 10,
2018, at 4:30 p.m., Eastern Standard Time, or as soon thereafter as is practicable.

In
connection with this request, the Registrant acknowledges that:

    ●
    should
    the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the
    filing effective, 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant 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.

Very
truly yours,

    ADM
    Endeavors, Inc.

    /s/
    Ardell Mees

    Ardell
    Mees

    Chief
    Executive Officer

CORRESP
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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

Mail Stop 4631

November 20, 2017

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

Re: ADM Endeavors, Inc.
Amendment No. 1  to Re gistration Statement on Form S -1
Filed November 13, 2017
  File No. 333 -220452

Dear Mr. Mees :

We have reviewed your amended 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.   Unless  we note
otherwise , our references to prior comments are to comments in our October 2, 2017  letter .

Recent Sales of Unregistered Securities, page 55

1. We note your response to prior commen t 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.

Ardell Mees
ADM Endeavors, Inc.
November 20, 2017
Page 2

  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 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.

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.

CORRESP
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November
10, 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.

    Registration
    Statement on Form S-1

    Filed
    September 14, 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 October
2, 2017, relating to the above-referenced filing.

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

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 reporting requirements.

    Response:
    We have included an additional risk factor to address this comment.

    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 both filings, please update this
    filing accordingly. Please refer to Securities Act Rule 429.

    Response:
    The Company does not intend to use a combined prospectus under Securities Act Rule 429 and has withdrawn the registration
    statement on Form S-1 (file number 333-201351), which was declared effective on May 14, 2015.

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.

    Response:
    We have revised accordingly.

    Recent Sales of Unregistered Securities, page 55

    4.
    We
    note your disclosure on page 15 that you issued 2,250,000 shares to Calvin 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 compensation 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.

    Response:
    We have revised accordingly.

Thank
you for your assistance and review.

Sincerely,

ADM
Endeavors, Inc.

    /s/
    Ardell Mees

    Ardell Mees

    Chief Executive Officer

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.

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    admcorresp05132015.htm

ADM Endeavors, Inc.

2021 N. 3rd Street

Bismarck, ND 58501

May 13, 2015

United States Securities and Exchange Commission

Attn: Pamela Long, Assistant Director

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re:     ADM Endeavors, Inc.

Registration Statement on Form S-1

File No. 333-201351

Ladies and Gentlemen:

The undersigned registrant (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-1 to become effective on May 14, 2015, at 4:00 p.m., Eastern Daylight Time, or as soon thereafter as is practicable.

In connection with this request, the Registrant acknowledges that:

should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

the Registrant 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.

Very truly yours,

ADM Endeavors, Inc.

/s/ Ardell Mees

Ardell Mees

Chief Executive Officer

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Securities and Exchange Commission

April 7, 2015

ADM ENDEAVORS, INC.

2021 N. 3rd Street

Bismarck, North Dakota 58501

April 7, 2015

Via Edgar

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington DC 20549

Attn: Pamela Long, Assistant Director

Re:         ADM Endeavors, Inc.

Amendment No. 2 to Registration Statement on Form S-1 Filed February 10, 2015

File No. 333-201351

Dear Ms. Long:

We have received your letter dated February 23, 2015 and have updated the Registration Statement and prepared the following responses to your comments.

General

1. Your current interim financial information is now stale since it is as of a date more than 45 days after your year-end of December 31, 2014.  Please note the Rule 8-08(b) of Regulation S-X requirement for audited financial statements of the most recently completed year when filing your next amendment, since the company reported losses from continuing operations for 2012 and it appears likely, based on the nine-month period ended September 30, that the company will be reporting a pre-tax loss during the most recently completed fiscal year.

RESPONSE: Financial statements have been updated to include the financial statement for the year ended December 31, 2014.

Selling Security Holders, page 16

2. Footnotes 2 and 3 do not appear to correspond with any text in this section.  Please revise.

RESPONSE: Footnotes 2 and 3 refer to selling security holders SLIC and STP Investments, respectively, found in column A of the Selling Security Holders table.  These numbers have been enlarged for better visibility.

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

3. Please provide the required disclosure of your financial condition and results of operations for the last two fiscal years.

RESPONSE: The MD&A section has been updated with the financial condition and results of operations disclosures for the last two fiscal years.

Securities and Exchange Commission

April 7, 2015

Results of Operations for the three months ended September 30, 2014 and 2013

4. Please clarify your disclosure in the fourth paragraph that any funds raised in this offering will go not to the Company but to your CEO.  We understand that the offering you are registering is for the resale of shares by selling shareholders, and the proceeds will go to the selling shareholders.

RESPONSE: The Registration Statement has been updated to reflect Results of Operations for the years ended December 31, 2014 and 2013.  The disclosure in question has been removed.

The Company acknowledges that:

·

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, 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 federal securities laws of the United States.

Sincerely,

ADM Endeavors, Inc.

/s/ Ardell Mees

Chief Executive Officer

February  23, 2015

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

Re: ADM Endeavors, Inc.
  Amendment No. 1 to Registration Statement on Form S-1
Filed  February 10 , 2015
  File No.  333-201351

Dear Mr. Mees :

We have reviewed your amendment and your letter dated February 10 , 2015, and we
have the following comments.

General

1. Your current interim fin ancial information is now stale since it is as of a date more than 45
days after yo ur year -end of December 31, 2014.  Please note the Rule 8 -08(b) of Regulation
S-X requirement for audited financial statements of the most recently completed year when
filing your next amendment , since the company reported losses from continuing operations
for 2012 and it appears likely , based on the nine -month period ended September 30,  that the
company will be reporting a pre -tax loss during the most recently completed fisc al year.

Selling Security Holders, page 16

2. Footnotes 2 and 3 do not appear to correspond with any text in this section. Please revise.

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

3. Please provide the required disclosure of your financial condition and results of operations
for the last two fiscal years.

Results of Operations for the three months ended September 30, 2014 and 2013

4. Please clarify your disclosure in the fourth paragraph that any funds ra ised in this offering
will go not t o the Company but to your CEO.  We understand that the offering you are

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

 registering is for the resale of shares by selling share holders, and the proceeds will g o to the
selling shareholders.

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  (via e -mail)
      Brunson Chandler & Jones, PLLC

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ADM ENDEAVORS, INC.

2021 N. 3rd Street

Bismarck, North Dakota 58501

February 9, 2015

Via Edgar

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington DC 20549

Attn: Pamela Long, Assistant Director

Re:          ADM Endeavors, Inc.

Registration Statement on Form S-1

Filed January 2, 2015

File No. 333-197610

Dear Ms. Long:

We have received your letter dated January 23, 2015 and have updated the Registration Statement and prepared the following responses to your 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.

RESPONSE: The correct target date for the district office in Kansas City, MO is September 1, 2015. The Registration Statement has been edited to reflect this correction.

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

RESPONSE: This risk factor has been deleted from the Risks Related to The Offering section of the Registration Statement.

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 dates of the transactions and the consideration paid by the selling security holders.

RESPONSE: We have updated the Selling Security Holders section to describe how the selling security holders acquired their securities they intend to sell.

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 Questions 140.02 of the Regulation S-K Compliance and Disclosure Interpretations.

RESPONSE: The natural persons who exercise voting and investment control for selling security holders that are not natural persons have been identified.

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.

RESPONSE: We have updated the Registration Statement to disclose any positions or material relationships that any selling security holder has had within the past three years.

6. Please tell us whether any of the selling security holders is a broker-dealer or an affiliate of a broker-dealer.  For any selling security holder who is a broker-dealer, the prospectus should state that the selling security 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 had no agreements or understandings, directly or indirectly, with any person 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 underwriter.  Note that broker-dealers and their affiliates need not be identified as underwriters.

RESPONSE: We have updated the Selling Security Holders section to disclose (based on representations we have received from Selling Security Holders) that none of the selling stockholders are broker-dealers or affiliates of broker-dealers.  Please see page 15.

Executive Compensation, page 31

7. Please revise this section to include Item 402 of Regulation 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.

RESPONSE: The salaries for the fiscal year ended December 31, 2014 have been added to the Executive Compensation section of the Registration Statement.

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

RESPONSE: We have updated the Registration Statement to provide management’s discussion and analysis of our financial condition for the interim period financial statements.

Exhibits, page 56

Exhibit 23.1

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

RESPONSE: We have had the auditor provide us with a revised consent letter to reference the appropriate date and file number and have included it as an exhibit to this Registration Statement.

The Company acknowledges that:

·

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, 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 federal securities laws of the United States.

Sincerely,

ADM Endeavors, Inc.

/s/ Ardell Mees

Chief Executive Officer

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

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ADM ENDEAVORS, INC.

2021 N 3rd Street

Bismarck, North Dakota 58501

Ardell Mees

Chief Executive Officer

2021 N 3rd St., Bismarck, ND 58501

Phone: (701) 226-9058

(Name, address and telephone number of
agent for service)

April 22, 2014

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Mail Stop 7010 100 F Street, NE

Washington, DC 20549

Pamela A. Long, Assistant Director

Edward M. Kelly, Senior Counsel

Era Anagnosti, Staff Attorney

Jenn Do, Staff Accountant

Alfred P. Pavot, Jr., Staff Accountant

    Re:
    ADM ENDEAVORS, INC. (the “Company”)

        Registration Statement on Form S-1

        File No. 333-191618

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, the Company hereby requests acceleration of the effective date of its Registration Statement on Form S-1 to
1:00 p.m. (Eastern Standard Time) on April 24, 2014 or as soon thereafter as is practicable.

In connection with the Company’s request
for acceleration of the effective date of its Registration Statement on Form S-1, the Company acknowledges the undertakings in
Rule 461 and that:

Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, 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 this action as defence in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance.

Very truly yours,

ADM ENDEAVORS, INC.

By: /s/ Ardell Mees

Ardell Mees

Chief Executive Officer

    1

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ADM ENDEAVORS,
INC.

2021 N. 3rd
Street Bismarck, N.D. 58501

701-226-9057
Fax-360-838-9500

tamees@btinet.net

April 16, 2014

Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C. 20549

Attn: 	    Pamela A. Long, Assistant Director

Era Anagnosti, Staff Attorney

Edward M. Kelly, Senior Counsel

Jenn Do, Staff Accountant

Alfred P. Pavot, Jr., Staff Accountant

Re: 	      ADM Endeavors, Inc.

Amendment No. 3 to Registration Statement on Form S-1

Filed April 4, 2014

File No. 333-191618

To Whom It May Concern:

On behalf of ADM Endeavors, Inc., a Nevada corporation (the “Company”), we submit the following responses which respond
to the numerical comments contained in the Securities and Exchange Commission letter dated April 10, 2014 (the “SEC Letter”)
regarding the Registration Statement on form S-1 (the “Registration Statement”).

Changes in Registrant's Certifying Accountant,
page 24

1. 	In accordance with the staff’s
comments, please be advised that the qualifying language has been removed.

Financial Statements

2. 	In accordance with the staff's comments,
please be advised that the financial statements have been placed inside the prospectus.

    1

Securities and Exchange Commission

Page Two

April 16, 2014

Report of Independent Registered Public
Accounting Firm, page F-1

3. 	Please be advised that the auditor's
report includes a going concern paragraph.

Exhibit 5.1

4. 	Please be advised that counsel's opinion
has been revised accordingly.

On behalf of the Company, we submit the following
acknowledgements:

 (a) the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;

 (b) staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to the filing; and

 (c) the Company may not assert staff comments as a defense in any proceeding
initiated by the Commission of any person under the federal securities laws of the United States.

Sincerely,

ADM Endeavors Inc.

By: /s/ Ardell D. Mees

Ardell D. Mees

President/Chief Executive Officer

    2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

        April 10 , 2014

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

 Re: ADM Endeavors,  Inc.
  Amendment No. 3  to Registration Statement on Form S -1
  Filed April 4 , 2014
 File No. 333 -191618

Dear Mr. Mees :

We have  reviewed the amended  filing and have the  comments  below .

Changes in Registrant’s Certifying Accountant, page 24

1. You disclose that “Other than an explanatory paragraph included in Rodgers’ audit report for
the Company's fiscal years ended December 31, 2012 and 2011 relating to the uncertainty of
the Company's ability to continue as a going concern, the audit report of Rodgers on the
company's financ ial statements for the fiscal years ended December 31, 2012 and 2011 and
through January 22, 2014, did not contain an adverse opinion or a disclaimer of opinion, nor
was it qualified or modified as to uncertainty, audit scope or accounting principles.”  We
note, however, that no such explanatory paragraph was included in Rodgers’ audit reports for
those periods in any of the prior filings. Please revise to remove the qualifying language from
the beginning portion of this sentence.

Financi al Statements

2. Please place your financial statements inside of the prospectus rather than at the back of the
registration statement.

Report of Independent Registered Public Accounting Firm, page F -1

3. We note your disclosure under the going concern heading on page 28.  Given your significant
working capital deficit, it is unclear why the audit report does not include a going concern

Mr. Ardell Mees
ADM Endeavors, Inc.
April 10 , 2014
Page 2

 paragraph consistent with the guidance in AU Section 341.  Please explain to us the factors
that your auditor considered in assessing the ne ed for a going concern paragraph.

Exhibit 5.1

4. Please have counsel revise the first paragraph of the opinion to refer to ADM Endeavors, Inc.
as the registrant and to reflect the registration statement’s correct filing date, October 8,
2013.

You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Alfred P. Pavot, Jr.,
Staff Accountant , at (202) 551 -3738  if you have questions about comments on the financial
statements and related matters.  You may contact  Edward M. Kelly, Senior Counsel,  at (202)
551-3728 or Era Anagnosti, Staff Attorney,  at (202) 55 1-3369 with any other questions.

       Very truly yours,

       /s/ Era Anagnosti

       for Pamela A. Long
       Assistant Director

cc: Via E -mail
 Diane D. Dalmy, Esq.
 2000 East 12th Avenue, Suite 32/10B
 Denver, CO 80206

CORRESP
1
filename1.htm

ADM ENDEAVORS,
INC.

2021 N. 3rd
Street Bismarck, N.D. 58501

701-226-9057
Fax-360-838-9500

tamees@btinet.net

 April 3, 2014

Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C. 20549

Attn: 	   Pamela A. Long, Assistant Director

Era Anagnosti, Staff Attorney

Edward M. Kelly, Senior Counsel

Jenn Do, Staff Accountant

Alfred P. Pavot, Jr., Staff Accountant

Re: 	     ADM Endeavors, Inc.

Amendment No. 1 to Registration Statement on
Form S-1

Filed January 23, 2014

File No. 333-191618

To Whom It May Concern:

On behalf of ADM Endeavors, Inc., a Nevada corporation (the “Company”), we submit the following responses which respond
to the numerical comments contained in the Securities and Exchange Commission letter dated March 25, 2014 (the “SEC Letter”)
regarding the Registration Statement on form S-1 (the “Registration Statement”).

Dealer Prospectus Delivery Obligation, pate
2

1. 	In accordance with the staff’s
comments, please be advised that the date has been revised in accordance with Item 502(b) of Regulation S-K.

Prospectus' Outside Front Cover Page

2. 	In accordance with the staff's comments,
we have deleted the phrase "until the common stock becomes quotes by a market maker..."

    1

Securities and Exchange Commission

Page Two

April 3, 2014

Plan of Distribution

3. 	In accordance with the staff's comments,
please be advised that the disclosure has been revised to state that the selling shareholder "is" an underwriter.

Experts

4. 	Please be advised that the firm of Patrick
Rodgers, CPA, P.A. was provided a copy of disclosure in the Registration Statement regarding his termination and as such has refused
to provide the Exhibit 16 letter. The Registration Statement has been revised to reflect his refusal to provide the Exhibit 16
letter.

Employment Agreements, page 35

5. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect consistent and accurate disclosure regarding the
executive salary for Mr. Mees.

6. 	In accordance with the staff’s
comments, please be advised that the Registration Statement has been revised to reflect that Mr. Mees' employment agreement was
amended on February 6, 2014 to remove Sections 3(d), (e) and (f) and that he was not paid any bonuses or commissions pursuant to
application of Sections 3(d) through (f) of the employment agreement.

7.	In accordance with the staff’s
comments, please be advised that the Registration Statement has been revised to reflect net income (loss) in the consolidated statement
of operations and cash flows.

On behalf of the Company, we submit the following
acknowledgements:

 (a) the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;

 (b) staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to the filing; and

 (c) the Company may not assert staff comments as a defense in any proceeding
initiated by the Commission of any person under the federal securities laws of the United States.

Sincerely,

ADM Endeavors Inc.

By: /s/ Ardell Mees

      President/Chief Executive Officer

    2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

        March 25 , 2014

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

 Re: ADM Endeavors,  Inc.
  Amendment No. 2  to Registration Statement on Form S -1
  Filed March 19 , 2014
 File No. 333 -191618

Dear Mr. Mees :

We have reviewed the amended  filing and have the  comments  below .

Dealer Prospectus Delivery Obligation, page 2

1. Refer to comment 13 in our February 6, 2014 letter.  We note that the revised date of March
19, 2014 continues to be inaccurate.  Please correct the date in accordance with Item 502(b)
of Regulation S -K.

Prospectus’ Outside Front Cover Page

2. Refer to comment one in our February 6, 2014 letter.   As requested previously, delete the
phrase “until the common stock becomes quoted by a market maker on the Over -the-Counter
Bulletin Board” in the first paragraph.

Plan of Distribution, page 17

3. Refer to comment six in our February 6, 2014 letter.  We n ote the revised disclosure that the
selling stockholder “is deemed to be” an underwriter.  Please revise to state that the selling
stockholder “is” an underwriter as you disclosed on the prospectus’ outside front cover page.

Mr. Ardell Mees
ADM Endeavors, Inc.
March 25 , 2014
Page 2

Experts, page 24

4. Please revise to disclose, if true, that you are unable to obtain an Exhibit 16 letter from
Patrick Rodgers, CPA, P .A. regarding your disclosure concerning him, as indicated in our
letter to you dated March 14, 2014.  If you are able to obtain the  letter, please file the letter as
an exhibit in your next amendment.

Employment Agreements, page 35

5. In the summary compensation table you disclose that Mr. Mees’ salary for fiscal year 2013
was $54,000.  You also disclose that pursuant to the Janua ry 3, 2013 employment  agreement ,
Mr. Mees  would receive an annual salary of $72,000.  Furthermore, you disclose that in
fiscal year 2013 you paid Mr. Mees  $67,524 in officer compensation.  With a view towards
disclosure, please explain to us why there is a discrepancy among the se three different
compensation amounts, and , to the extent necessary, please revis e your disclosures
accordingly .  We note a similar discrepancy with respect to the 2012 compensation.

6. Refer to comment 12 in our letter dated February 6, 2014.  Please revise your disc losure to
indicate that Mr. Mees’ employment agreement was amended on February 6, 2014 (see
Exhibit 10.7 to the registration statement) to remove Sections 3(d), (e) , and (f) of the
agreement.  Please confirm that prior to the amendment of the employment ag reement, Mr.
Mees was not paid any bonuses or commissi ons pursuant to the application  of Sections 3(d)
through (f) of the agreement.

Consolidated Statements of Operations, page F -3

7. Please revise  to indicate that there was net income for 2013 instead of net loss.

Mr. Ardell Mees
ADM Endeavors, Inc.
March 25 , 2014
Page 3

You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Alfred P. Pavot, Jr.,
Staff Accountant , at (202) 551 -3738  if you have questions about comments on the financial
statements and related  matters.  You may contact  Edward M. Kelly, Senior Counsel,  at (202)
551-3728 or Era Anagnosti, Staff Attorney,  at (202) 55 1-3369 with any other questions.

       Very truly yours,

       /s/ Era Anagnosti

       for Pamela A. Long
       Assistant Director

cc: Via E -mail
 Diane D. Dalmy, Esq.
 2000 East 12th Avenue, Suite 32/10B
 Denver, CO 80206

CORRESP
1
filename1.htm

ADM ENDEAVORS,
INC.

2021 N. 3rd
Street Bismarck, N.D. 58501

701-226-9057
Fax-360-838-9500

tamees@btinet.net

March 19, 2014

Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C. 20549

Attn: 	Pamela A. Long, Assistant Director

Era Anagnosti, Staff Attorney

Edward M. Kelly, Senior Counsel

Jenn Do, Staff Accountant

Alfred P. Pavot, Jr., Staff Accountant

Re: 	ADM Endeavors, Inc.

Amendment No. 1 to Registration Statement on Form S-1

Filed January 23, 2014

File No. 333-191618

To Whom It May Concern:

On behalf of ADM Endeavors, Inc., a Nevada corporation (the “Company”), we submit the following responses which respond
to the numerical comments contained in the Securities and Exchange Commission letter dated February 6, 2014 (the “SEC Letter”)
regarding the Registration Statement on form S-1 (the “Registration Statement”).

Prospectus Outside Front Cover Page

1. 	In accordance with the staff’s
comments, we have removed the requested disclosure regarding pricing as it relates to a primary offering. .

2. 	In accordance with the staff's comments,
we have added further disclosure regarding termination date of the offering.

3. 	In accordance
with the staff's comments, the last sentence has been revised to reflect that the offering constitutes a primary offering and the
amount of securities registered will be offered and sold within two years from the effective date at which time the offering will
terminate.

    1

Securities and Exchange Commission

Page Two

March 19, 2014

4. 	In accordance with the staff's comments,
the disclosure referencing the "mining exploration industry" has been deleted.

Any future market price for our shares may
be volatile, page 16

5. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised deleting reference to "financial literacy products and
industry". We have also deleted reference to fluctuations of exchange rates between foreign currency and the U.S. Dollar.

Plan of Distribution, page 20

6. 	In accordance with the staff’s
comments, please be advised that the Registration Statement has been revised to indicate that the selling stockholder is an underwriter.

Shares issued for consulting services, page
25

7. 	In accordance with the staff’s
comments, please be advised that the disclosure has been revised to identify the related party consultant.

Revenues, page 32

8. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to identify the states where the Company intends to increase
sales presence and that the Company will not be receiving any funds raised in the offering.

Liquidity and Capital Resources, page 35

9. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect that each of the Company’s five targeted expansion
areas will require approximately $200,000 each in start-up capital for a total of $1,000,000 over a two year rollout period.

    2

Securities and Exchange Commission

Page Three

March 19, 2014

Executive Compensation, page 38

10. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to provide disclosure regarding executive compensation, including
fiscal year ended December 31, 2013.

11. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect the issuance of the 20,000,000 shares of Series A
convertible preferred stock, the value per share and that the Series A preferred shares were issued as compensation.

Employment Agreements, page 39

12. 	In accordance with the staff's comments,
please be advised that the disclosure has been revised elaborating on the terms and provisions of Mr. Mees' employment agreement,
including Sections 3(d) and (f).

Dealer Prospectus Delivery Obligation, page
39

13. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to correct the date in accordance with Item 502(b) of Regulation
S-K.

Signatures, page 46

14. 	In accordance with the staff's comments,
please be advised that the principal financial officer and principal accounting officer and each person's executive position has
been specifically referenced.

Financial Statements

15. 	In accordance with the staff's comments,
we have noted the financial statement updating requirements in Article 8-08 of Regulation S-X.

    3

Securities and Exchange Commission

Page Four

March 19, 2014

Note 7, Stockholders' Equity, page F-11

16. 	In accordance with the staff's comments,
please be advised that the footnote has been amended to reflect that shares issued as compensation are recorded at par value of
$0.001 per share.

Exhibits

17. 	In accordance with the staff's comments,
please be advised that the Certificate of Designation has been filed as an exhibit.

18. 	In accordance with the staff’s
comments, please be advised that the "Form of Subscription Agreement" has been deleted.

Exhibit 23.1

19. 	In accordance with the staff's comments,
please be advised that consent has been updated to current date.

On behalf of the Company, we submit the following
acknowledgements:

 (a) the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;

 (b) staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to the filing; and

 (c) the Company may not assert staff comments as a defense in any proceeding
initiated by the Commission of any person under the federal securities laws of the United States.

Sincerely,

ADM Endeavors Inc.

By: /s/ Ardell D. Mees

Ardell D. Mees

President/Chief Executive Officer

    4

March  14, 2014
Via E -mail
Mr. Ardell Mees
Chief Executive Officer
ADM Endeavors, Inc.
2021 North 3rd Street
Bismarck, ND 58501

Re:  ADM Endeavors, Inc.
 Amendment No. 1 to Registration Statement on Form S -1
 Filed January 23, 2014
 File No. 333 -191618

Dear  Mr. Mees :

We note that your financial statements for the years ended December 31, 2012 and 2011,
were audited by  Patrick Rodgers, CPA, PA .  Effective  March  6, 2014 , the Public Company
Accounting Oversight Board ("PCAOB") revoked the registration of Patrick Rodgers, CPA, PA .
You can find a copy of the order at
http://pcaobus.org/Enforc ement/Decisions/Documents/2014_Rodgers.pdf

As Patrick Rodgers, CPA, PA is no longer registered with the PCAOB;  you may not
include its audit reports or consents in your filings with the Commission .  If Patrick Rodgers,
CPA, PA  audited a year that you are required to include in your filings with the Commission,
you should have a firm that is registered with the PCAOB re -audit that year.

 In providing the information required by  Item 304 of Regulation S -K in your amended
Form S -1, please also indicate tha t the PCAOB has revoked the registration of your prior auditor,
Patrick Rodgers, CPA, PA .  We believe the revocation of the accountant’s PCAOB registration
and the reasons thereto would likely be information necessary to make the required statements –
whet her the former accountant resigned, declined to stand for re -election or was dismissed – in
light of the circumstances under which they are made not misleading.  If you are unable to obtain
an Exhibit 16 letter from Patrick Rodgers, CPA, PA at the time you  file, please disclose this fact.
Once you explain  Patrick Rodgers, CPA, PA ’s registration revocation in a Form S -1, you do not
need to repeat this disclosure in your next Form 10 -K.  If you have any questions, please contact
me at (202) 551 -3355 .

Sincer ely,

/s/ Terence O’Brien

Terence O’Brien
Accounting Branch Chief

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

        February 6, 2014

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

 Re: ADM Endeavors,  Inc.
  Amendment No. 1 to Registration Statement on Form S -1
  Filed January 23, 2014
 File No. 333 -191618

Dear Mr. Mees :

We have  reviewed the amended filing and have the  comments  below .

Prospectus Outside Front Cover Page

1. Refer to comment six in our November 4, 2013 letter.  Since this is a primary offering which
must be conducted at a fixed price for its entire duration, delete the phrase “until the common
stock becomes quoted by a market maker on the Over -the-Counter Bulletin Board” in the
fifth sen tence in the first paragraph.  Similarly, revise the first paragraph under “Plan of
Distribution” on page 20 to remove the statement that “These sales may be at fixed or
negotiated prices.”

2. As previously requested in comment seven in our November 4, 2013 letter, please identify
here the offering period.

3. Please revise the last sentence of the first paragraph to state that you expect  the amount of
securities being registered to be sold within two years from the effective date of the
registration statement.

4. Since the company is engaged in providing installation services to grocery décor design
companies, we assume that the reference to “risks generally associated with the mining
exploration industry” is inadvertent.  Please revise your disclosure accordingly .

Mr. Ardell Mees
ADM Endeavors, Inc.
February 6, 2014
Page 2

Any future market price for our shares may be volatile, page 16

5. Since the company is engaged in providing installation services to grocery décor design
companies, we assume that the references to financial literacy products and financial literacy
educa tion industries under (iii) and (iv) in the first paragraph is inadvertent.  Please delete.
Additionally, since the company’s operations are in the United States, the relevance of the
reference to fluctuations of exchange rates between foreign currency an d the U.S. dollar
under (vii) in the first paragraph is unclear.  Please revise or advise.

Plan of Distribution, page 20

6. We note disclosure in the seventh paragraph that the selling stockholder and any broker -
dealers “might be deemed” to be underwriters in connection with the sale of the shares.
Revise to indicate that the selling stockholder is an underwriter and that any broker -dealer
may be deemed to be an underwriter.

Shares issued for consulting services, page 25

7. We note your revised disclos ure in response to comment 22 in our November 4, 2013 letter.
Please identify the related party consultant.  See Item 404(a)(1) of Regulation S -K.

Revenues, page 32

8. We reissue comment 30 in our November 4, 2013 letter since y ou have not revised your
disclosure to identify the states where you intend to increase your sales presence.  In
addition, since the company will receive no proceeds from this offering, revise the last
sentence in the second paragraph which states that “th e Company will use funds raised in this
offering…”

Liquidity and Capital Resources, page 35

9. We note your revised disclos ure in response to comment 35 in our November 4, 2013 letter.
Please quantify the known or estimated amount of additional funding tha t management
believes it will need to support operating activities in the next 12 months.

Executive Compensation, page 38

10. Please update executive compensation disclosure for the fiscal year ended December 31,
2013.  In this regard, please revise the seco nd paragraph to indicate that the table summarizes

Mr. Ardell Mees
ADM Endeavors, Inc.
February 6, 2014
Page 3

 compensation paid to your named executive officers rather than directors.  See Item 402(n)
of Regulation S -K.  Additionally, please provide disclosure regarding compensation of
directors as required by Ite m 402(r) of Regulation S -K.  Alternatively, if directors are not
compensated for their service, so indicate.

11. We note that on page 42 you now disclose that the 20 million shares of Series A co nvertible
preferred stock issue d to the chief executive officer “for services performed on behalf of the
Company” were canceled on September 20, 2013.  Please clarify whether these shares were
issued to the CEO as compensation for his services as an officer of the company.  To the
extent that the s hares were issued as compensation (despite their being cancelled), the
amount of such earned compensation may represent compensation which should be disclosed
on the summary compensation table in accordance with Item 402 of Regulation S -K.  Please
advise.

Employment Agreements, page 39

12. Refer to Mr. Ardell Mee s’ 2013 employment agreement filed as Exhibit 10.4.  Please expand
your disclosure  to elaborate on the provisions of Sections 3(d) and (f) of the agreement since
they appear ambiguous.  For example , please explain what a consulting client is, what would
trigger payment of a commission, and whether a monthly benchmark of $50,000 refers to the
commission payable or to the fees collected from a consulting client.  If Mr. Mees has been
paid these commis sions in  the past, please disclose the  amounts earned and/or paid pursuant
to the requirements of Item 402(n).  Please also explain what products are “co -created,” and
what is spli t “60% ADM 40% Ardell Mees.”

Dealer Prospectus Delivery Obligation, page 39

13. We assume that the revised disclosure “Until January 22, 2014” made in response to
comment 3 in our November 4, 2013 letter is inadvertent .  Please correct the date in
accordance with  Item 502(b) of Regulation S -K.

Signatures, page 46

14. Refer to comment 42 in our November 4, 2013 letter.  Your principal financial officer and
principal accounting officer or controller also must sign the registration statement.
Additionally, any person who occupies more than one of the specified positions must indicate
each capacity in which he signs the registration statements.   See Instructions 1 and 2 for
signatures on Form S -1, and revise.

Mr. Ardell Mees
ADM Endeavors, Inc.
February 6, 2014
Page 4

Financial Statements

15. Please note the financial statement updating requirements in Article 8 -08 of Regulation S -X.

Note 7 – Stockholders’ Equity, page F -11

16. We have read your revisions regarding stock compensation in comment s 31 and 44 in our
November 4, 2013  letter .  It remains unclear to us how $1.00 per share is an appropriate
valuation of your common shares, giv en, among other things , minimal assets and cash flows
as well as net losses in all periods. Therefore, please amend your financial statements to
reflect that shares issued as compens ation are recorded at par value or $.001 per share  unless
you can provide objective and reliable evidence supporting an alternative fair value amount.
Refer to ASC 845 -10-30 and 820 -10-35.

Exhibits

17. We note your response to comment 46 in our November 4, 2013 letter.  We are unable to
locate the exhibit containing the certifica te of designation.  Please advise or otherwise file it
with your next amendment.

18. We not e your response to comment 48 in our November 4, 2013 letter; however, you still list
the “Form of Subscription Agreement” as exhibit 10.2 in the exhibit index.  Pleas e revise the
exhibit index accordingly.

Exhibit 23.1

19. Please update the consent to refer to the appropriate amendment of the registration statement.

Mr. Ardell Mees
ADM Endeavors, Inc.
February 6, 2014
Page 5

 You may contact Jenn Do , Staff Accountant, at (202) 551 -3743 or Alfred P. Pavot, Jr.,
Staff Accountant , at (202) 551 -3738  if you have questions about comments on the financial
statements and related matters.  You may contact  Edward M. Kelly, Senior Counsel,  at (202)
551-3728 or Era Anagnosti, Staff Attorney,  at (202) 55 1-3369 with any other questions.

       Very truly yours,

       /s/ Era Anagnosti

       for Pamela A. Long
       Assistant Director

cc: Via E -mail
 Diane D. Dalmy, Esq.
 2000 East 12th Avenue, Suite 32/10B
 Denver, CO 80206

CORRESP
1
filename1.htm

ADM ENDEAVORS,
INC.

2021 N. 3rd
Street Bismarck, N.D. 58501

701-226-9057
Fax-360-838-9500

tamees@btinet.net

January 22, 2014

Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C. 20549

Attn: 	Pamela A. Long, Assistant Director

          Era Anagnosti, Staff Attorney

          Edward M. Kelly, Senior Counsel

          Jenn Do, Staff Accountant

         Alfred P. Pavot, Jr., Staff Accountant

Re: 	 ADM Endeavors, Inc.

        Registration Statement on Form S-1

        Filed October 8, 2013

        File No. 333-191618

To Whom It May Concern:

On behalf of ADM Endeavors, Inc., a Nevada corporation (the “Company”), we submit the following responses which respond
to the numerical comments contained in the Securities and Exchange Commission letter dated November 4, 2013 (the “SEC Letter”)
regarding the Registration Statement on form S-1 (the “Registration Statement”).

Registration Statement's Facing Page

1. 	In accordance with the staff’s
comments, we have checked the box accordingly to indicate that the shares are being offered pursuant to Rule 415.

Calculation of Registration Fee, page 2

2. 	In accordance with the staff's comments,
the subparagraph of Rule 457(o) has been noted regarding reliance for purpose of calculating the registration fee.

    1

Securities and Exchange Commission

Page Two

January 22, 2014

Dealer Prospectus Delivery Obligation

3. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised regarding the date and removal of legend to outside back cover
of the prospectus.

Prospectus Outside Front Cover Page

4. 	In accordance with the staff’s
comments, please be advised that the Registration Statement has been revised to limit the outside cover page to one page as required
by Item 501(b) of Regulation S-K and the disclosure regarding emerging growth company status and the fact that the Company has
elected to take advantage of the extended transition period for complying with new or revised accounting standards has been placed
within the Prospectus.

5. 	In accordance with the staff’s
comments, please be advised that the disclosure has been revised to reflect that Mr. Ardell, as the only selling shareholder is
also the Company's CEO.

6. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been amended to reflect that the offering constitutes a primary offering.

7. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to delete reference to sales by Mr. Mees as an affiliate under
Rule 144 and to specify termination of the offering two years from the effective date.

8. 	In accordance with the staff's comments,
please be advised that the duplicative "Subject to Completion" legend has been removed.

9. 	In accordance with the staff's comments,
please be advised that the net proceeds to the selling stockholder on an aggregate basis have been disclosed.

Our Business, pages 6 and 23

10. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to disclose how long the Company has been an operating business.

11. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect the specific geographic areas in which the Company
has current operations and where it is seeking to expand operations.

    2

Securities and Exchange Commission

Page Three

January 22, 2013

Summary Financial and Operating Information,
page 7

12. 	Please be advised that the financial
statements and summary presentation financial figures are reconciled. Please be further advised that the Registration Statement
has been updated with financial statements and associated disclosure for the quarter ended September 30, 2013.

Disclosure Regarding Forward-Looking Statements,
page 8

13. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect that the Company does not plan to update the forward-looking
statements contained in the Prospectus other than as required by law.

Risks Factors

Construction and production capacities that
do not match demand for ourproducts could result in lost sales ....page 9

Our failure to manage growth could harm
it, page 10

14. 	In
accordance with the staff's comments, please be advised that these two risk factors have been revised to delete reference to "manufacturing"
capacity and "engineering resources" to better describe the Company's business operations.

We may depend on OEMs..... page 11

We may purchase key grocery store components
and products from single or limited sources .....page 11

15. 	In accordance with the staff's comments,
please be advised that the risk factor has been revised to disclosure that the Company's primary suppliers of components that it
installs in grocery stores is also the largest source of its contracts. The disclosure further identified such suppliers.

Purchasers in this offering will have limited
control over decision making.....page 14

16. 	In accordance with the staff's comments,
please be advised that the risk factor has been revised addressing the equity ownership of Mr. Mees and his wife together with
potential conflicts of interest.

    3

Securities and Exchange Commission

Page Four

January 22, 2014

Determination of Offering Price, page 15

17. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to delete reference to a limited operating history while disclosing
elsewhere the Company's inception history.

Selling Security Holdings, page 16

18. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to disclose the nature of the transaction involving Mr. Mees'
acquisition of the shares and all relevant associated information.

19. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to provide tabular disclosure of the amount and percentage of
the class of securities owned by Mr. Mees after the offering.

Directors, Executive Officers, Promoters
and Control Persons, page 18

20. 	In accordance with the staff's comments,
please be advised that the biographical information regarding Larry Aamold and Chramaine Matteis has been revised to include specific
experience, qualifications, attributes and skills regarding their respective position as a member of the Company's Board of Directors.

Certain Relationships and Related Transactions,
page 20

21. 	In accordance with the staff's comments,
please be advised that the Registration Statements has been revised to reflect that Ardell Mees and Tammera Mees are husband and
wife. The disclosure of such fact has also been made throughout the Registration Statement where pertinent.

Shares issued for consulting services, page
20

22. 	In accordance with the staff's comments,
please be advised that the nature of the consulting services rendered by Calvin Mees and the value of the 2,250,000 shares of common
stock issued to Mr. Mees for such consulting services has been included in the Registration Statement. Please be further advised
that such disclosure has been made regarding the 20,000,000 shares of Series A preferred stock issued to Ardell Mees for executive
services.

    4

Securities and Exchange Commission

Page Five

January 22, 2014

Common Stock, page 21

23. 	In accordance with the staff's comment,
please be advised that the Registration Statement has been revised to reflect that shareholders have full cumulative voting rights
associated with election of directors.

Validity of Securities, page 22

24. 	In accordance with the staff's request,
please be advised that the Registration Statement has been revised to include counsel's address.

Description of Business, page 23

General

25. 	In accordance with the staff's request,
please be advised that the Registration Statement has been revised disclosing the Company's dependency on its two major customers
and a risk factor has been included.

Our Business, page 23

26. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to reflect that the Company acquired all of the assets of ADM
Enterprises LLC and that ADM Endeavors Inc. was a North Dakota corporation re-domiciled to Nevada.

27. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to clarify that the Company previously conducted its business
through the LLC entity until 2008 and that it is now the Company's wholly-owned subsidiary.

28. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised regarding anticipated timeline for establishing an online presence.

Our Target Markets and Marketing Strategy,
page 23

29. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to clearly reflect the Company's current target market.

    5

Securities and Exchange Commission

Page Six

January 22, 2014

Management's Discussion and Analysis of
Financial Condition and Results of Operations, page 25

Revenues, page 25

30. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to identify the states in the midwestern United States where
the Company's plans to increase its sales presence.

Operating Activities, page 26

31. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to describe the nature of the consulting services for which
the Company issued $562,500 of stock as compensation.

Liquidity and Capital Resources, page 27

32. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to quantify how much additional funding is required to support
the Company's operating activities in the next twelve months and its long term liquidity needs.

33. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to delete reference to use by the Company of offering proceeds.

34. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to include disclosure regarding the material decrease in the
value of the Company's fixed assets based upon full depreciation.

35. 	In accordance with the staff's comments,
please be advised that the Registration Statement has been revised to disclose that the Company has not entered into any arrangements
for raising capital necessary to finance its operations nor are there any outstanding loans.

    6

Securities and Exchange Commission

Page Seven

January 22, 2014

Executive Compensation, page 30

36. 	In accordance with the staff’s
comments, please be advised that the employment agreement with Ardell Mees has been filed as an exhibit.

37. 	In accordance with the staff's comments,
please be advised that the executive compensation table in the Registration Statement has been revised to include Ardell Mees'
full salary.

Recent Sales of Unregistered Securities,
page 33

38. 	In accordance with the staff’s
comments, please be advised that the Registration Statement has been revised to reflect incorporation date of January 4, 2001.

Undertakings, page 34

39. 	In accordance with the staff’s
comments, please be advised that the undertakings under paragraphs 4 and 5(b) as well as the Rule 430A undertakings have been deleted.

40. 	In accordance with the staff's comments,
please be advised that the undertaking under paragraph 5 and 5(a) have been revised so that they conform exactly to the undertakings
specified in Item 512 of Regulation S-K.

41. 	In accordance with the staff's comments,
please be advised that the undertaking under paragraph 2 has been deleted as redundant.

Signatures, page 36

42. 	In accordance with the staff's comments,
please be advised that the principal financial officer and principal accounting officer and majority of the members of the Board
of Directors have signed the Registration Statement.

Financial Statements

43. 	In accordance with the staff's comments,
please be advised that the accrued expenses in the statement of cash flows has been reconciled with the figures in the balance
sheet accounts.

    7

Securities and Exchange Commission

Page Eight

January 22, 2014

Note 6, page F-11

44. 	In accordance with the staff's comments,
please be advised that the footnote has been amended to disclose management's analysis regarding establishment of the $1.00 per
share initial public offering price. Please be further advised that Registration Statement has been revised to include filing of
the employment agreement with Calvin Mees as an exhibit.

45. 	In accordance with the staff's comments,
please be advised that the footnote has been revised reflecting that the preferred shares have been cancelled.

Exhibits

46. 	In accordance with the staff’s
comments, please be advised that the Certificate of Designation has been filed as an exhibit to the Registration Statement.

Exhibit 5

47. 	In accordance with the staff's comments,
please be advised that counsel's opinion has been revised accordingly.

Exhibit 10.2

48. 	In accordance with the staff's comments,
please be advised that the document referencing a confidential private placement memorandum has been deleted.

Exhibit 23

49. 	In accordance with the staff's comments,
please be advised that the consent has been updated as well as the financial statements to reflect quarter ended September 30,
2013.

    8

Securities and Exchange Commission

Page Nine

January 22, 2014

On behalf of the Company, we submit the following
acknowledgements:

 (a) the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;

 (b) staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to the filing; and

 (c) the Company may not assert staff comments as a defense in any proceeding
initiated by the Commission of any person under the federal securities laws of the United States.

Sincerely,

ADM Endeavors Inc.

By: /s/ Ardell D. Mees

Ardell D. Mees

President/Chief
Executive Officer

    9

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

        November 4 , 2013

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

 Re: ADM Endeavors,  Inc.
  Registration Statement on Form S -1
  Filed October 8 , 2013
 File No. 333 -191618

Dear Mr. Mees :

We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us information so that 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 that our comments apply to your facts and
circumstances or do not believe an amendment is app ropriate, 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.

Registration Statement’s Facing Page

1. Since the se curities being registered are to be offered on a delayed or continuous basis
pursuant to Rule 415 under the Securities Act, please check the Rule 415 box.

Calculation of Registration Fee, page 2

2. Indicate in footnote (1) the subparagraph of Rule 457 under  the Securities Act upon which
you relied for the purpose of calculating the registration fee.

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 2

Dealer Prospectus Delivery Obligation

3. We assume that the date “Until October 8, 2013” is an inadvertent error.  Please revise.  In
addition, consider relocating this disclosure on the outside back cover of the prospectus.
Refer to Item 502(b) of Regulation S -K.

Prospectus’ Outside Front Cover Page

4. Limit the outside cover page to one page as required by Item 501(b) of Regulation S -K.  In
this regard, please consider relocating the emerging growth company disclosure in another
section of the filing.  In addition, please revise the emerging growth company disclosure to
clearly state that you have elected to take advantage of the extended transition perio d for
complying with new or revised accounting standards pursuant to Section 107(b) of the JOBS
Act.

5. Since Mr. Ardell Mees, the company’s CEO, is the only selling stockholder, revise the
disclosure here and, as appropriate, elsewhere in the registration s tatement to indicate that
fact.

6. You disclose that Mr. Ardell Mees, the only selling stockholder, is “an underwriter…”  We
also note that in your Plan of Distribution disclosure on page 16 you disclose that the selling
stockholder “might be deemed to be” a n underwriter.
 If the offering constitutes a primary offering by or on behalf of the issuer, then the
offering must be conducted at a fixed priced for the entire duration of the offering
period.  Since the offe ring would then appear to be conducted in compliance with
Rule 415(a)(1)(ix) under the Securities Act, then at the time the registration statement
becomes effective, the amount of securities registered should be reasonably expected
to be offered and sold within  two years from the effective date.  Please see Rule
415(a)(2) under the Securities Act.  For additional guidance, refer to Question 212.6
of the Securities Act Rules section in our  Compliance and Disclosure Interpretations
available on the Commission’s  website.  Please advise, or otherwise revise your
disclosures throughout the reg istration statement, including Plan of Distribution
disclosure to reflect that the offering represents a primary offering. To the extent
necessary, please consider adjusting the offering amount accordingly to ensure
compliance with Rule 415(a)(2).
 If the CEO was inadvertently identified as an underwriter on the prospectus cover
page and you believe that  his offering of securities represents a secondary offering
within the ambit of Rule 415(a )(1)(i) under the Securities Act, then please provide us

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 3

 a detailed legal analysis on why the sale of the shares by the CEO should be regarded
as a secondary offering that is eligible to be made on a delayed or continuous basis
under Rule 415(a)(1)(i) rath er than as a primary offering.  For additional guidance,
please see Item 612 .09 of the Securities Act Rules  Compliance and Disclosure
Interpretations available on the Commission’s  website.  We may have additional
comments follow ing the review of your response.

7. Please identify here the offering period.  In this regard, we note your “Termination of the
Offering” disclosure on page 7.  To the extent that the selling stockholder is considered to be
a statutory underwriter in connect ion with this offering, then the selling stockholder may not
rely on Rule 144 for the sale of any of the securities covered by the registration statement.
Please consider identifying an actual date when the offering will terminate.

8. Please remove the dupl icative “Subject to Completion” legend.

9. Please disclose the net proceeds to the selling stockholder on an aggregate basis.   Refer to
Item 501(b)(3) of Regulation S -K.

Our Business, pages 6 and 23

10. Briefly disclose how long you have been an operating business.

11. Disclose the specific geographic area in which you have current operations and the additional
geographic areas in which you are seeking to expand your operations.  We note the broad
reference to your market area of the Midwest on page 24.

Summa ry Financial and Operating Information, page 7

12. The numbers included in your summary presentation do not correspond with your financial
statement numbers.  For example, for fiscal year 2012, your financial statements on page F -
14 indicate sales of $225,415  while the summary presentation on page 8 lists revenues f or the
same period of $147,137.   Please note that this is only one example.  Please reconcile  your
disclosures accordingly.

Disclosure Regarding Forward -looking Statements, page 8

13. Please revise t he last paragraph of your disclosure to state that you do not plan to update the
forward -looking statements contained in the prospectus other than as required by law.

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 4

Risk Factors, page 9

Construction and production capacities that do not match demand fo r our products could result in
lost sales…, page 9
Our failure to manage growth could harm it, page 10

14. We note that in these two risk factors you refer to “manufacturing” capacity and “engineering
resources.”  Since you describe your business as providin g “customized construction and
installation of grocery store décor” (see “Our Business” disclosure on page 23), please revise
your disclosure to provide a clearer understanding of what type of manufacturing capabilities
you have and briefly describe the en gineering resources you possess and how they relate to
your business operations.

We may depend on OEMs…, page 11
We may purchase key grocery store components and products from single or limited sources…,
page 11

15. You state that original component manufac turers “may produce some of your products lines”
or that you “may purchase” some products from single or limited sources.  With a view
towards disclosure, please tell us whether you are currently dependent on OEMs or any
single supplier and how such depend ence may have affected your business.  To the extent
necessary, please also observe the disclosure requirements of Item 101(h)(4)(v) of Regulation
S-K.

Purchasers in this offering will have limited control over decision making…, page 14

16. Since you are incorporated in Nevada, the relevance of the reference to “provisions of
California law” is unclear.  Please revise.  In addition, please consider adding a separate risk
factor disclosure addressing conflicts of interest which may arise given Mr. Mees’ substantial
owne rship interest.

Determination of Offering Price, page 15

17. The statement that you have a limited operating history appears inconsistent with disclosure
on page 18 that you have a 25 year history.  Please reconcile the disclosures.

Selling Security Holders , page 16

18. Briefly describe here the material terms of the transaction(s) pursuant to which Mr. Mees

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 5

 acquired the shares covered by the registration statement.  Please ensure to indicate when the
private placement transaction(s) took place, the total consi deration received by the company,
as well as describe any rights attached to the shares ( i.e., registration rights).

19. Please revise the tabular disclosure to include the amount, not only the percentage, of the
class of securities owned by the selling secur ity holder after the offering.  Refer to Item 507
of Regulation S -K.

Directors, Executive Officers, Promoters and Control Persons, page 18

20. With respect to Mr. Larry Aamold and M s. Chramaine Matteis , please revise their
biographical information to discuss  the specific experience, qualifications, attributes , or skills
that led to the conclusion that he or she  should serve as your director in light of your business
and structure.  Please refer to Item 401(e) (1) of Regulation S -K.

Certain Relationships and R elated Transactions, page 20

21. Please disclose if there is a family relationship between Mr. Ardell Mees and M s. Tammera
Anne Mees.

Shares issued for consulting services, page 20

22. Please disclose the nature of consulting services rendered by Mr. Calvin Mee s.  Disclose also
the value of the 2,250,000 shares of common stock issued to Mr. Calvin Mees for consulting
services.  We note the disclosure on page 33 that issuance of the shares resulted in a
consulting expense of $562,500.  See Item 404(a)(3) of Regul ation S -K.  Please comply with
this comment also with respect to the  20 million Series A preferred s hares issued to Mr.
Ardell Mees for executive services.

Common Stock, page 21

23. Disclose whether holders of your shares of common stock have cumulative voting rights in
the election of directors.  Refer to Item 202(a)(1) of Regulation S -K.

Validity of Securities, page 22

24. Please provide counsel’s address as required by paragraph 26 of Schedule A to the Securities
Act.

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 6

 Description of Business, page 23

General

25. We note the disclosure on page 26 that the majority of your revenues are obtained from two
customers, Super Valu, Inc. and Associated Wholesale Grocers.  Disclose in the business
section your dependence on these two major customers.  See Item 101(h)(4)(vi) of
Regulation S -K.  Additionally, advise what consideration you have given to risk factor
disclosure of your dependence on these two major customers.

Our Business, page 23

26. Please revise your disclosure to state that you acquired all o f the assets of ADM Enterprises,
LLC rather than ADM Enterprises, Inc., on July 1, 2008 and not on January 5, 2001.  In
addition, at the end of the paragraph correctly state that ADM Endeavors, Inc. was a North
Dakota corporation which was l ater redomicile d to Nevada.

27. Based on the share e xchange transacti on, it appears that the company , even though initially
incorporate d in 2001 under the laws of  North Dakota  and redomiciled to  Nevada in 2006 ,
conducted its business through the LLC entity until 2008.  If tru e, please clarify this fact in
your disclosures.  In addition, since you state that ADM Enterprises LLC became your
wholly owned subsidiary, please describe the types of activities currently carried on by your
subsidiary , and file with your next amendment a list of the company’s subsidiaries as Exhibit
21.

28. Please disclose the timeframe that you anticipate for  establishing an online presence.

Our Target Markets and Marketing Strategy, page 23

29. You state that you believe that your primary target market “will consist of various large retail
grocers…”  As it appears that you have operated in the same industry for several years,
please revise your disclosure to indicate your current target market.

Management’s Discussion and Analysis of Financial Condition and Results of O perations, page
25

Revenues, page 25

30. Please i dentify in which states in the mid western Unites States you plan to increase your
sales presence.

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 7

Operating Activities, page 26

31. Please revise to describe the nature of the consulting services provided by the  related party
during the  six months ended June 30, 2013  for which you issued $562,500 of stock as
compensation.

Liquidity and Capital Resources, page 27

32. Please revise to quantify how much additional funding you believe is needed to support
operati ng ac tivities in the next 12  months, including “plans to hire and train future sales
managers who will work from a satellite office in the mid -western United States” and costs
to open the  satellite o ffice.  Please discuss your long term liquidity needs as discus sed in
Section 501.03.a of the Codification of Financial Reporting Policies.

33. Please revise the statement on page 25 about using offering proceeds to fund a satellite
office , given that you will receive  no proceeds from this offering.

34. You state that your total  current assets for fiscal year 2012 and for the period ended June 30,
2013 were mainly comprised of cash assets.  We note that your balance sheet indicates
properties and equipment , net of $3,987 and $3,527 for each respective period.  We also note
that E xhibit 2 of the share exchange a greement (Exhibit 10.1) lists assets and property
interests acquired by the corporate entity during the share exchange , valued at $119,085.00.
With a view towards disclosure, please explain to us what caused the material dec rease in the
value of your assets.

35. Please disclose whether you have entered into any arrangements for raising any funding
necessary to finance your operations.  In this regard, we note that you obtain loans from
shareholders as a means to finance your bus iness operations.  Please also revise your
disclosure to describe the material terms of the loan arrangements, and file as exhibits any
loan agreements entered into with your loaning shareholders, or otherwise tell us why you
would not be required to do so .  Note that if the company is party to an oral contract that
would be required to be filed as an exhibit under Item 601(b)(10) of Regulation S -K if it
were written, the company should provide a written description of the contract similar to that
required for oral contracts or arrangements under Item 601(b)(10)(iii) of Regulation S -K.
For guidance you may wish to refer to Question 146.04 in the Regulation S -K section of our
Compliance and Disclosure Interpretations available on the Commission’s website.

Mr. Ardell Mees
ADM Endeavors, Inc.
November 4 , 2013
Page 8

 Executive Compensation, page 30

36. Please file Mr. Ardell Mees’ employment agreement as an exhibit with your next
amendment.

37. You disclose that Mr. Ardell Mees’ employment agreement provides for a salary of $72,000;
however, in the salary column of the summar y compensation table you disclose $15,823
which is the amount of salary he was paid in 2012.  To the extent that Mr. Mees has earned
the salary contemplated by the terms of the employment agreement, that amount must be
disclosed in the summary compensation  table.  Refer to Item 402(n)(2)(iii) of Regulation S -
K.  Please advise , or otherwise revise your disclosure accordingly.

Recent Sales of Unregistered Securities, page 33

38. Please revise the disclosure in the opening paragraph to indicate January 4, 2001 as the
company’s incorporation date rather than May 9, 2006, which was the date the company was
converted into a Nevada corporation.

Undertakings, page 34

39. The undertakings under paragraphs “4)” and “5)b” as  well as th