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January 8, 2024
Rafael Pinedo
President and Principal Executive Officer
CAM Group, Inc.
5900 Balcones Drive,
Suite 100
Austin, TX 78731
Re:CAM Group, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Filed December 18, 2023
File No. 024-12339
Dear Rafael Pinedo:
            We have reviewed your amended offering statement and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 2, 2023, letter.
Amendment No. 1 to Offering Statement on Form 1-A, Filed December 18, 2023
Risk Factors
Our Business Model is Evolving
Manage potential future acquisitions, investments, divestitures, joint ventures and other
transactions successfully, these activities..., page 17
1.We note your disclosure on page 30 that you plan to engage in mergers and acquisition
activity in England, France and other NATO countries. Please amend this risk factor, or
create a new risk factor, to highlight that you may lose the benefit of a Regulation A
exemption in the event your principal place of business shifts to outside the United States
or Canada.

 FirstName LastNameRafael Pinedo
 Comapany NameCAM Group, Inc.
 January 8, 2024 Page 2
 FirstName LastName
Rafael Pinedo
CAM Group, Inc.
January 8, 2024
Page 2
Description of the Business
Organization and History, page 29
2.We note your response to comment 5 and reissue. We acknowledge your amended
disclosure stating that the March 22, 2022, agreement was with Technomeca Defense,
Inc., rather than with Mr. Rafael A. Pinedo. However, since Mr. Pinedo
directs Technomeca Defense, Inc. and is now also the President and CEO of the
Company, please provide the information required by Item 13 of Form 1-A (Interest of
Management and Others in Certain Transactions) or tell us why you believe such
information is not required.
Exhibits
3.Please file or advise why you believe the March 22, 2022, agreement to purchase the
control block of CAMG should not be filed under Item 17 of Form 1-A.
General
4.We note your response to comment 1 and reissue in part. We acknowledge the inclusion
of a new Amended and Restated Articles of Incorporation; however, your file on the
website for the Nevada Secretary of State still states that you have authorized 100,000,000
shares of common stock. Please clarify this discrepancy.
            Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Frank I Igwealor, Esq.