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December 1, 2022
Christopher P. Kalnin
Chief Executive Officer
BKV Corporation
1200 17th Street, Suite 2100
Denver, CO 80202
Re:BKV Corporation
Registration Statement on Form S-1
Filed November 18, 2022
File No. 333-268469
Dear Christopher P. Kalnin:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our November 10, 2022 letter.
Registration Statement on Form S-1
Glossary of Oil and Natural Gas Terms, page iii
1.We have read your response to prior comment 4 and note the updated S-1 glossary
contains definitions for proved reserves, probable reserves, possible reserves, and proved
developed reserves which are related to the Petroleum Resources Management System.
Please revise these definitions to conform with the Securities and Exchange
Commission's Regulations Par 210.4-10(a) and to correlate with those used in your third
party reserve reports.

 FirstName LastNameChristopher P. Kalnin
 Comapany NameBKV Corporation
 December 1, 2022 Page 2
 FirstName LastName
Christopher P. Kalnin
BKV Corporation
December 1, 2022
Page 2
Summary Reserve, Production and Operating Data
Estimated Reserves at SEC Pricing, page 30
2.We have read your response to prior comment 5 and note your inclusion of probable and
possible reserves disclosures in the Form S-1. However, based on your third party reserve
reports these volumes include both probable developed and probable undeveloped
reserves and possible developed and possible undeveloped reserves. Expand your
disclosure further to separately present the volumes related to each of these reserve
categories.
3.We have read your response to prior comment 6 and note your detailed explanation of the
changes in proved developed and proved undeveloped reserves does not provide a
breakout of the 19.5 MMcfe of minerals in place purchased during 2021. Please expand
your disclosures on pages 33, 107-108 and 191 of Form S-1 to include an explanation of
proved developed vs. proved undeveloped for these volumes.
Estimated Reserves at NYMEX Strip Pricing, page 34
4.Based on our review of the third party reserve reports filed as Exhibits 99.14 to 99.18, the
Form S-1 presentation of Estimated Reserves at NYMEX Strip Pricing appears to include
two incorrect values on pages 35 and 192. The first is the value for "Total Estimated
Proved Reserves (MMcfe)" under "Estimated Proved Reserves at NYMEX Strip Pricing,"
and the second is the value for "Natural Gas Liquids (MBbls)" under "Estimated Probable
Reserves at NYMEX Strip Pricing." Please verify or correct the values disclosed.
Barnett Assets
Supplemental Oil and Gas Information (unaudited), page F-88
5.Your response to prior comment number 37 from our letter dated October 13, 2022
indicates that you were not “provided” with reserve studies for the acquired properties.
However, Rule 3-05(f)(1) of Regulation S-X provides for an alternative reserve
computation in cases where “prior year reserve studies were not made”.  Clarify for us
whether prior year reserve studies were made for the acquired properties.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759 or Jenifer
Gallagher, Staff Accountant, at (202) 551-3706 if you have questions regarding comments on the
financial statements and related matters. You may contact Sandra Wall, Petroleum Engineer, at

 FirstName LastNameChristopher P. Kalnin
 Comapany NameBKV Corporation
 December 1, 2022 Page 3
 FirstName LastName
Christopher P. Kalnin
BKV Corporation
December 1, 2022
Page 3
(202) 551-4727 with questions about engineering comments. Please contact Karina Dorin, Staff
Attorney, at (202) 551-3763 or Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642
with any other questions
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Samantha Hal Crispin