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January 8, 2024

Division of Corporation Finance

Office of Mergers & Acquisitions

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Avelan Enterprise Ltd.

Cama Commercial Group, Corp.

Clarendon Worldwide S.A.

Almacenes Éxito S.A.

Schedule TO-T filed December 18, 2023

SEC File No. 5-94183

Ladies and Gentlemen:

On behalf of our clients,
Cama Commercial Group, Corp., Clarendon Worldwide S.A. and Avelan Enterprise Ltd. (the “Offerors”), we are writing to
submit the Offerors’ responses to the comments you provided on behalf of the staff (the “Staff”) of the Division of
Corporation Finance, Office of Mergers & Acquisitions, of the U.S. Securities and Exchange Commission (the
“Commission”) set forth in its letter, dated December 29, 2023, relating to the Offerors’ Schedule TO-T filed on
December 18, 2023 (the “Schedule TO-T”). Contemporaneously, the Offerors are supplementally providing the Staff with a
draft of an amended Offer to Purchase (the “Amended Offer to Purchase”) and the related Notice of Acceptance for Shares,
in each case marked to show proposed revisions to reflect the Offerors’ responses to the Staff’s comments set forth
below. The Offerors have also filed with the Commission an amendment to the Schedule TO-T (including the Amended Offer to
Purchase and Notice of Acceptance).

We have set forth below the
comments of the Staff in bold and the Offerors’ response thereto. Please note that all page numbers are references to the Amended
Offer to Purchase. Capitalized terms not otherwise defined in this letter have the meanings ascribed to them in the Amended Offer to Purchase.

Schedule TO-T filed December 18, 2023

What are the conditions to the Colombian Offer?,
page 6

 1. The disclosure here states that the Colombian Offer is subject to the same “conditions” as
the U.S. Offer. However, earlier disclosure indicates there is only a single condition (the Minimum Condition) to consummation of the
U.S Offer. Please revise or advise.

Response: In response to the Staff’s comment, the Offerors confirm that there is only a single condition to the U.S. Offer,
the Minimum Condition. The Offerors have revised the disclosure on page 6 of the Amended Offer to Purchase to clarify that the Colombian
Offer is subject to the same Minimum Condition as the U.S. Offer.

    Page 2

    January 8, 2024

Background of the Offers, page 12

 2. We note the disclosure at the top of page 13 that consummation of the Offers will result in Purchaser
acquiring an interest in Tuya, which requires approval of the SFC under Article 88 of the Colombian Financial System Organic Statute.
We also note that Grupo Calleja has filed a request seeking such approval. Please expand to discuss the anticipated timing of this approval,
whether the Offers can close without it, and what will happen if approval is ultimately not received. Your revised disclosure should take
into account the maximum permitted offer period for the Colombian Offer permitted by Colombian law.

Response: Grupo Calleja received Article 88 approval from the SFC on December 26, 2023. Accordingly, the Offerors have revised
the disclosure on page 13 of the Amended Offer to Purchase to reflect receipt of the requisite SFC approval for the indirect acquisition
of the Tuya interest on December 26, 2023.

Purpose of and Reasons for the Offers, page
13

 3. Here or in an appropriate section of the Offer to Purchase, please prominently discuss the filing persons’
ability to control and integrate Éxito, assuming the Offers are successfully consummated at a participation level of 51%, including
any limitations on their ability to acquire any remaining shares in a squeeze out merger pursuant to Colombian law. Any differences between
Colombian and U.S. law should be highlighted. If the threshold for full control/integration is above the Minimum Condition, please highlight
this fact (specifying the threshold percentage needed for a “squeeze out,” if applicable) and explain its implications, in particular,
for remaining Éxito shareholders.

Response: The Offerors acknowledge
the Staff’s comment and advise the Staff that under Colombian law, any person holding 50% +1 share of the outstanding shares of
a company can control the company through its corporate governance structure. Such person will have (a) the ability to approve matters
requiring a simple majority of Shares1 and
(b) the legal right and ability to elect the majority of the board of directors of the company. Assuming the Offers are successfully
consummated at a participation level of 51%, the Purchaser will have the ability to control Éxito.

In response to the Staff’s comment, the Offerors have
revised the disclosure on page 13 of the Amended Offer to Purchase to explicitly state that Colombian law does not provide for the ability
of an acquirer to conduct a “squeeze-out” merger to acquire any remaining Shares held by any non-tendering shareholders of
Éxito. The disclosure has been further revised to note that at 51% ownership of the Shares, Purchaser would have (i) the ability
to approve or reject matters requiring a simple majority vote of Shares and (ii) the legal right and ability to elect a majority of the
board of directors of Éxito pursuant to Colombian law. Therefore, the Offerors advise the Staff that the Minimum Condition represents
the legal threshold for full control under Colombian corporate law.

 1 Under Colombian law, certain extraordinary actions require the
approval of a special majority vote of shareholders. These actions include dividend distribution (78% shareholder vote required), issuance
of shares without preemptive rights (70% shareholder vote required) and payment of dividends in shares (80% shareholder vote required).

    Page 3

    January 8, 2024

Because no “squeeze-out”
provision applies in this case, and as already disclosed on page 13 of the Amended Offer to Purchase, the Purchaser could seek to acquire
up to 5% of the Shares in the secondary market through trades on the Colombian Stock Exchange (the “BVC”) or through private
acquisitions. If the percentage ownership that the Purchaser is seeking to acquire is equal to or greater than 5% of the issued and outstanding
Shares of Éxito, under BVC rules, the Purchaser could only acquire Shares of the remaining Éxito shareholders through either
(i) a public tender offer (oferta pública de adquisición, or “OPA”) like the Colombian Offer, or (ii)
a tender offer with the explicit intention of going private (OPA de Desliste, or “going private tender offer”). In
either scenario, participation in the tender offer is voluntary and not compulsory for minority shareholders. The Offerors do not have
any current plans to launch a subsequent tender offer or to delist Éxito.

In addition, as already disclosed on
page 14 of the Amended Offer to Purchase, after completion of the Offers, the number of Shares and ADSs remaining in public circulation
may decrease, and the market for such securities may be even further reduced. The Offerors also note that if the Purchaser acquires 51%
of the Shares in the Offers, 47.36% of the Shares (which are comprised of Shares and Shares underlying ADSs and BDRs held by the Sellers
and subject to restrictions on transfer) would be Shares that are not currently part of the public float. As a result, the reduction of
the public float could be as little as 3.64% of the outstanding Shares.

Certain Effects of the Offers, page 14

 4. We note the following statement on page 14: “To the extent that Purchaser’s percentage ownership
of Éxito is increased pursuant to the Offers, its interests in the net book value and net earnings of Éxito will increase
correspondingly.” State the percentage of Éxito held by Purchaser or any other filing person or their affiliates before the
Offers. We may have additional comments.

Response: The Purchaser and all
other filing persons and their affiliates do not have any ownership interest in Éxito prior to or during the Offers. Accordingly,
the Offerors have revised the disclosure on page 14 of the Amended Offer to Purchase to disclose this fact and to clarify that the statement
noted in the comment reflects the Purchaser’s intent after consummation of the Offers.

 5. We note the disclosure that “Purchaser may convert the Company into a closely-held corporation
or cancel the registration of its Shares in the Securities Registry of the SFC. The Offerors may cause the Shares to be de-listed from
the BVC.” Please revise to disclose more fulsomely and prominently the impact of these changes on remaining holders of Shares who
do not tender into the Offers.

Response: In response to the Staff’s comment, the Offerors have revised the disclosure on page 14 of the Amended Offer to
Purchase to explicitly disclose that, consistent with other disclosures in the Amended Offer to Purchase, the Offerors may, but do not
currently intend to, make another tender offer similar to the current Offer or a going private tender offer (OPA de Desliste) of
Éxito’s Shares in Colombia or the U.S.

    Page 4

    January 8, 2024

 6. Under NYSE Listing on page 15, revise to provide a greater understanding of how likely it is that the
ADSs will be involuntarily de-listed from the NYSE after the Offers. Provide an estimation of how many ADSs would need to remain outstanding
to avoid de-listing. Provide similar disclosure regarding deregistration in the following section on the same page.

Response: The Offerors respectfully advise the Staff that page 15 of the Amended Offer to Purchase already includes disclosure
of the relevant quantitative NYSE continued listing standards (based on the number of ADSs, ADS holders and trading volume), which provide
ADS holders with a sense of how many ADSs would need to remain outstanding to avoid de-listing.

In response to the Staff’s comment,
the Offerors have revised the disclosure in the Amended Offer to Purchase as follows:

    ●
    Page 15 of the Amended Offer to Purchase has been revised to include the most recently available outstanding number of ADSs and trading volumes for the most recent four months (as the ADSs began trading on the NYSE on August 23, 2023) to provide ADS holders with the appropriate context for assessing Éxito’s potential risk of non-compliance with the NYSE listing standards.

 ● The disclosure under “Reporting Obligations and Registration Under the Act” on page 15 of
the Amended Offer to Purchase has been revised to include the numeric standards for deregistration under the Securities Exchange Act of
1934 pursuant to Rule 12h-6.

Risks of Tendering Shares in the Colombian
Offer instead of the U.S. Offer, page 16

 7. We note your disclosure that “the terms and conditions of the U.S. Offer and the Colombian Offer
are substantially similar.” Please disclose the differences between the conditions in the U.S. Offer and those in the Colombian Offer.
See our comment below regarding certain differences we have identified.

Response: In response to the Staff’s comment, please see the responses to Comment 10, which are incorporated here by reference.

    Page 5

    January 8, 2024

General

 8. We note that the Offerors will apparently not undertake a second-step “squeeze out” merger
of any remaining Shares not acquired in the Offers. We also note that the Minimum Condition is a simple majority of the issued and outstanding
Shares on a fully diluted basis. Given that if the Offers are consummated, the filing persons will become majority owners of Almacenes
Éxito, please provide your analysis supplementally as to the materiality of Clarendon’s and other filing person’s financial statements
here. See Item 10 of Schedule TO. Your analysis should address the fact that Almacenes Éxito is incorporated in Colombia, which
fact may affect the filing persons’ ability to control or integrate the target into another entity, and their ability to eliminate target
shareholders who do not tender into the Offers, and therefore, could bear on the materiality of the bidders’ financial statements in the
context of this unsolicited Offer for a target company that is a foreign private issuer. In addition, your response should discuss the
fact that financing for the Offers is not yet in place, based on the disclosure on page 35 that “the definitive documentation for
the loan facility is subject to further review and negotiation.”

Response: In response to the Staff’s
comment, the Offerors believe that their financial condition is not material to the holders of the Shares or ADSs in the U.S. Offer because
the U.S. Offer meets the conditions for omitting bidder financial statements pursuant to Item 10 of Schedule TO:

 ● the U.S. Offer is for all outstanding securities of the subject class (i.e., the Shares and the ADSs),

 ● the consideration for the U.S. Offer consists solely of cash and,

 ● there is no financing condition to the U.S. Offer.

While the Offerors acknowledge that the
Commission believes that the financial condition of a bidder may be material where a bidder seeks to acquire a significant equity stake
to acquire control of the target, the Offerors respectfully note that the instructions to Schedule TO provide clear criteria for determining
when financial statements are not required. Furthermore, the Offerors respectfully submit that Offerors’ current plans with respect
to Éxito if the Offers are consummated do not give rise to the type of concerns that would make their financial statements material
to Éxito shareholders.

As described in the Amended Offer to
Purchase, the Purchaser and the Offerors are ultimately controlled by Francisco Calleja Malaina who also controls Grupo Calleja, which
owns the leading grocery retailer group in El Salvador, with a history of over 75 years, a presence in all 14 states of El Salvador and
a 60% market share in the country. Éxito is the sixth largest food retailer in South America, and the largest in Colombia and Uruguay,
with a presence in Colombia, Uruguay and Argentina and over 70 years of retail experience in Colombia. For the nine months ended September
30, 2023, Éxito reported gross revenues of COP$15.7 trillion, gross profit of COP$4.1 trillion and net income of COP$7.2 billion.
The proposed acquisition of control of Éxito is part of Grupo Calleja’s strategy to expand its business to other parts of
Latin America where it does not currently have a presence. As a result, the Purchaser’s interest in acquiring control of Éxito
is to establish a grocery retail presence in Colombia, Uruguay and Argentina where it does not currently have a presence. However, Purchaser
has no current plans to integrate Éxito into Grupo Calleja’s grocery retail business in El Salvador. As discussed above,
the Offerors have no present intention to de-list the Shares or the ADSs and expect that Éxito will continue to maintain a separate
system of financial reporting for its investors following consummation of the Offers (as is currently the case). Purchaser’s information
will not be consolidated with Éxito for purposes of financial reporting under Colombian exchange regulations.

    Page 6

    January 8, 2024

The Purchaser expects to have the ability
to control the board of directors of Éxito through its ownership of at least 51% of the Shares. However, it does not anticipate
that there would be any significant changes in corporate governance, other than replacing GPA Casino appointed directors with directors
appointed by Purchaser or one of its affiliates.

In addition, the Offerors note that notwithstanding
their acquisition of control of Éxito, as long as Éxito ADSs continue to be listed on the NYSE and its Shares are listed
on the Colombian Stock Exchange following completion of the Offers, Éxito will be required continue to maintain three independent
directors (under the independe