Correspondence 0001903596-24-000436 from CAM GROUP, INC. (CAMG) (CIK 0001419559) (CAMG)
CAM GROUP, INC. (CAMG) (CIK 0001419559)
Date: July 29, 2024 · CIK: 0001419559 · Accession: 0001903596-24-000436
AI Filing Summary & Sentiment
File numbers found in text: 024-12339
Letter
Re: CAM Group, Inc.
CAM Group, Inc.
Balcones Drive
Suite
Austin, TX 78731
July 29, 2024
Amendment No. 2 to Offering Statement on Form 1-A
Filed February 9, 2024
File No. 024-12339
Dear: Mr. Nicholas Nalbantian
Please see the answer to your comments below.
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.
We have updated the filing with the "Mid" and "Min" allocations part restored.
General
2. 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 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.
We have updated the Offering Circular to show the Company has not yet obtained any contract, even though the current officers have identified a number of Defense and Aerospace contract that the Company could pursue as a prime contractor or subcontractor.
Please contact me at ra.pinedo@camgdefense.com or capitalmarketssecurities@gmail.com with further inquiries.
Thank you.
Sincerely,
/s/
Rafael Pinedo
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CAM
Group, Inc.
5900
Balcones Drive
Suite
100
Austin,
TX 78731
July
29, 2024
Re:
CAM Group, Inc.
Amendment
No. 2 to Offering Statement on Form 1-A
Filed
February 9, 2024
File
No. 024-12339
Dear:
Mr. Nicholas Nalbantian
Please
see the answer to your comments below.
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.
We
have updated the filing with the "Mid" and "Min" allocations part restored.
General
2. 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
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.
We
have updated the Offering Circular to show the Company has not yet obtained any contract, even though the current officers have identified
a number of Defense and Aerospace contract that the Company could pursue as a prime contractor or subcontractor.
Please
contact me at ra.pinedo@camgdefense.com or capitalmarketssecurities@gmail.com with further inquiries.
Thank
you.
Sincerely,
/s/
Rafael Pinedo
Rafael
Pinedo
Chairman,
CAM Group, Inc.