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
 Ardell Mees
FirstName LastNameArdell Mees
ADM Endeavors, Inc.
Comapany NameADM Endeavors, Inc.
May 29, 2019
May 29, 2019 Page 2
Page 2
FirstName LastName
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.
 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,
FirstName LastNameArdell Mees
                                                           Division of
Corporation Finance
Comapany NameADM Endeavors, Inc.
                                                           Office of
Manufacturing and
May 29, 2019 Page 3                                        Construction
FirstName LastName