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CORRESP
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CAM Group, Inc.

5900 Balcones Drive

Suite 100

Austin, TX
78731

December 18, 2023

Re:        CAM
Group, Inc.

Offering
Statement on Form 1-A

Filed
October 13, 2023

File
No. 024-12339

To whom it may concern:

Please see the answer to your comments
below.

Offering Statement on Form
1-A filed October 13, 2023

Cover Page

 1. We
                                            note that you plan to make an offering of 600,000,000 shares of common stock. However, your
                                            charter states that you have authorized only 100,000,000 shares of common stock, which on
                                            its face is insufficient to accommodate the proposed offering. Please tell us how you plan
                                            to proceed.

This has been amended to
reflect a new authorized of 700,000,000 as shown in the latest article filed on 12/18/2023.

 2. Please
                                            disclose on the cover page that there is substantial doubt about your ability to continue
                                            as a going concern. Please include a cross-reference to the going concern disclosure elsewhere
                                            in the offering circular.

The cover page has been revised
to provide the going concerns disclosure.

Description of Business

Organization and History,
page 26

 3. We
                                            note your disclosure on page 27 that you are currently contemplating a merger with Technomeca
                                            Defense, Inc., an entity headquartered in Spain. Please clarify how you intend to remain
                                            eligible under Rule 251(b)(1) of Regulation A if the merger with a Spanish entity occurs.

The contemplated acquisition
of Technomeca Defense, Inc., if and when it occurs, would be part of series of aerospace/defense operations in the United States and
with a little part of those acquisition inside NATO. Technomeca Defense, Inc is a Texas Corporation. Technomeca Aerospace SA is a Spanish
corporation, and would become a subsidiary of Technomeca Defense, Inc after the acquisition. None of our proposed international subsidiaries,
if/when acquired would be major stay of our operations.

 4. We
                                            note your disclosure on page 26 that CAM Group Inc. previously managed "CAM Group,"
                                            which included a Hong Kong entity referred to as "CAM HK" and a Hebei Province
                                            entity referred to as "CAM Hebei." Please clarify your disclosure here, and the
                                            corresponding section in the F-Pages, as to whether these two Chinese entities are still
                                            part of your business. Alternatively, if these entities have been dissolved, please state
                                            as much. In addition, we note that on the cover page you define CAM Group Inc. as the "Company."
                                            However, on page 26 you define the "Company" as "CAMG, CAM HK and CAM Hebei,"
                                            please clarify this discrepancy.

This has been amended to include
additional narrative regarding the current makeup of the company’s assets, businesses and current subsidiaries.

 5. Please
                                            update and clarify the status of the proposed merger with Technomeca Defense, Inc. In addition,
                                            regarding the Technomeca transaction, 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.

This has been amended to
show that the proposed acquisition of Technomeca Defense, Inc. Has not been consummated and that even after a consummation of the proposed
acquisition, Technomeca would remain a minor subsidiary of the Company.

 6. Regarding
                                            the judgment against the company that you learned about on August 16, 2022, and your subsequent
                                            appeal, please provide a materially complete description of the matter.

This has been amended to
provide further disclosures to show the requested information about the lawsuit that led to the award and the details of the appeal filed.

General

 7. We
                                            note the inclusion of financial statements for the years ended December 31, 2022 and 2021.
                                            Please revise the offering circular to also provide an interim balance sheet as of a date
                                            no earlier than six months after the most recently completed fiscal year end. Refer to Part
                                            F/S(b)(3)(B) of Form 1-A.

This has been amended to
provide additional disclosure to add the financial statements for the period ended June 30, 2023.

 8. In
                                            addition to qualifying a Regulation A offering with the Commission, issuers in Tier 1 offerings
                                            must register or qualify their offering in any state in which they seek to offer or sell
                                            securities pursuant to Regulation A. Please provide a written representation confirming that
                                            at least one state has advised the company that it is prepared to qualify or register the
                                            offering..

We’re currently preparing
to submit the Offering for registration with the States of Texas, Wyoming and Colorado.

Please contact me
at ra.pinedo@camgdefense.com or capitalmarketssecurities@gmail.com with further inquiries.

Thank you.

Sincerely,

/s/ Rafael
Pinedo

Rafael Pinedo

Chairman, JPX Global,
Inc.