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PATTON BOGGS LLP

2001 ROSS AVENUE, SUITE 3000

DALLAS, TEXAS 75201

214-758-1550

November 16 , 2005

VIA EDGAR

Securities and Exchange Commission

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

    Attn:

    John Reynolds

Assistant Director

Division of Corporation Finance

    Re:

    JK Acquisition Corp. Amendment No. 7 to Registration Statement on Form S-1

Registration Statement No. 333-125211

Dear Mr. Reynolds:

     JK Acquisition Corp. (the “Company”) has previously filed with the Commission an Amendment No.
7 to the above referenced Registration Statement (the “Registration Statement”). The changes
reflected in Amendment No. 7 were intended to respond to the comments set forth in (i) your letter
dated September 19, 2005 (the “Comment Letter”) and (ii) the Key Hospitality Acquisition
Corporation letter, dated October 12, 2005, from the SEC to Kenneth R. Koch (the “No-Action
Response Letter”). The changes made in response to the Comment Letter and No-Action Response
Letter are discussed below. The numbered paragraph below corresponds to the numbered comment in
the Comment Letter. Within our response, page references are to the pages in the Prospectus
included in the Registration Statement filed with the Commission on November 2, 2005.

    2.

    Please address the applicability or inapplicability of Regulation M in the context of the
warrant repurchase agreements contained discussed in your principal stockholders section.

    RESPONSE: We have revised the Registration Statement, including Exhibit 10.11 (the Warrant
Purchase Agreement) to represent that:

    (a)

    Other than the bid represented by the Warrant Purchase Agreement, no
warrant bids or purchases pursuant to the Warrant Purchase Agreement will occur
until 60 calendar days following the end of the restricted period for the unit
distribution;

Division of Corporation Finance

Attn: John Reynolds

November 16, 2005

Page 2

    (b)

    Ferris, Baker Watts, Incorporated shall keep, and produce promptly upon
request a daily time-sequenced schedule of all warrant purchases made pursuant to
this agreement, on a transaction-by-transaction basis, including (i) size, time of
execution, price of purchase; and (ii) the exchange, quotation system, or other
facility through which the warrant purchase occurred; and

    (c)

    The warrant purchases will be made pursuant to a pre-established
agreement in accordance with the guidelines of Rule 10b5-1 under the Securities
Exchange Act.

    Moreover, upon the request of the Securities and Exchange Commission — Division of
Market Regulation, the Company and Ferris, Baker Watts, Incorporated shall transmit a
daily time-sequenced schedule of all warrant purchases made pursuant to this agreement,
on a transaction-by-transaction basis, including (i) size, time of execution, price of
purchase; and (ii) the exchange, quotation system, or other facility through which the
warrant purchase occurred to the Division of Market Regulation at its headquarters in
Washington, DC within 30 days of its request. And representatives of the Company and
Ferris, Baker Watts, Incorporated shall be made available (in person at the offices of
the Division of Market Regulation in Washington, DC or by telephone) to respond to
inquiries by the Division of Market Regulation regarding any such warrant purchases.

    We believe that these revisions, as marked in Exhibit 10.11 and on pages 12, 14 and 40 of
the Prospectus, demonstrate our compliance with the guidelines and conditions set forth in
the No-Action Response Letter that the Division of Market Regulation provided to us.

If you have any questions regarding this request, please do not hesitate to contact me at (214)
758-6621 or Fred Stovall at (214) 758-1515.

Very truly yours,

/s/ Thad A. Schaefer

Thad A. Schaefer, Esq.

    cc:

    Fred S. Stovall, Esq.

Elizabeth Marino, Special Counsel, Division of Market Regulation (via electronic mail)

Duc Dang, Division of Corporation Finance (via electronic mail)