SEC Comment Letter 0000000000-24-008102 to CAM GROUP, INC. (CAMG) (CIK 0001419559) (CAMG)
CAM GROUP, INC. (CAMG) (CIK 0001419559)
Date: July 17, 2024 · CIK: 0001419559 · Accession: 0000000000-24-008102
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 024-12339
Letter
July 17, 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. 3 to Offering Statement on Form 1-A Filed July 9, 2024 File No. 024-12339 Dear Rafael Pinedo: We have reviewed your amended offering statement and have the following comment(s). 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 February 14, 2024 letter. Amendment No. 3 to Offering Statement on Form 1-A, Filed July 9, 2024 Use of Proceeds, page 25 1.We note you have removed the "Mid" and "Min" proceeds allocations from this section and kept only the "Max" allocation; however, elsewhere in the offering statement you keep language referring to a range of different amounts you expect to raise. Please restore the previous "Mid" and "Min" allocations, or please explain why the "Mid" and "Min" allocations are no longer needed. General We note your updated disclosure on page 8 from "provides" to "seeks to provide." Please confirm, if true, if this indicates that CAM Group Inc. is not currently acting as a government contractor. If you are not currently acting as a government contractor, please update the rest of the offering statement to clarify your current status. As non-exclusive 2.
July 17, 2024 Page 2 examples, we note that on page 12 you say you " depend on a small number of customers, " on page 13 you say you are already a " prime contractor " indicating that you are currently acting as a government contractor, and on page 29 you use the heading "Current Operations" to describe activities that you plan to pursue but that are not actually current operations of your business. 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.
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July 17, 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. 3 to Offering Statement on Form 1-A
Filed July 9, 2024
File No. 024-12339
Dear Rafael Pinedo:
We have reviewed your amended offering statement and have the following comment(s).
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 February 14, 2024 letter.
Amendment No. 3 to Offering Statement on Form 1-A, Filed July 9, 2024
Use of Proceeds, page 25
1.We note you have removed the "Mid" and "Min" proceeds allocations from this section
and kept only the "Max" allocation; however, elsewhere in the offering statement you
keep language referring to a range of different amounts you expect to raise. Please restore
the previous "Mid" and "Min" allocations, or please explain why the "Mid" and "Min"
allocations are no longer needed.
General
We note your updated disclosure on page 8 from "provides" to "seeks to provide." Please
confirm, if true, if this indicates that CAM Group Inc. is not currently acting as a
government contractor. If you are not currently acting as a government contractor, please
update the rest of the offering statement to clarify your current status. As non-exclusive 2.
July 17, 2024
Page 2
examples, we note that on page 12 you say you " depend on a small number of customers, "
on page 13 you say you are already a " prime contractor " indicating that you are currently
acting as a government contractor, and on page 29 you use the heading "Current
Operations" to describe activities that you plan to pursue but that are not actually current
operations of your business.
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.