SEC Comment Letter 0000000000-22-013680 to BKV Corp (BKV) (CIK 0001838406) (BKV)
BKV Corp (BKV) (CIK 0001838406)
Date: Dec. 19, 2022 · CIK: 0001838406 · Accession: 0000000000-22-013680
AI Filing Summary & Sentiment
File numbers found in text: 333-268469
Letter
United States securities and exchange commission logo December 19, 2022 Christopher P. Kalnin Chief Executive Officer BKV Corporation 1200 17th Street, Suite 2100 Denver, CO 80202 Re:BKV Corporation Amendment No. 1 to Registration Statement on Form S-1 Filed December 9, 2022 File No. 333-268469 Dear Christopher P. Kalnin: We have reviewed your amended 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 December 1, 2022 letter. Amendment No. 1 to Registration Statement on Form S-1 Summary Reserve, Production and Operating Data Estimated Reserves at SEC Pricing, page 31 1.After consideration of your response to prior comment number 3 and further review of 2021 Activity on pages 35 to 36, the overall reconciliation of changes in proved developed and proved undeveloped reserves does not appear to account for the 19.4 Bcfe of proved undeveloped reserves converted to proved developed reserves disclosed on page 35. Please expand your narrative to identify where these converted volumes are included in the reconciliation. Refer to the requirements in Item 1203 of Regulation S-K, FASB ASC 932-235-50-5 description of proved reserves change categories, and Example 1 in FASB ASC 932-235-55-2 for an illustration.
FirstName LastNameChristopher P. Kalnin Comapany NameBKV Corporation December 19, 2022 Page 2 FirstName LastName Christopher P. Kalnin BKV Corporation December 19, 2022 Page 2 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 (202) 551-4727 with questions about engineering comments. Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Samantha Hal Crispin
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United States securities and exchange commission logo
December 19, 2022
Christopher P. Kalnin
Chief Executive Officer
BKV Corporation
1200 17th Street, Suite 2100
Denver, CO 80202
Re:BKV Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed December 9, 2022
File No. 333-268469
Dear Christopher P. Kalnin:
We have reviewed your amended 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 December 1, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-1
Summary Reserve, Production and Operating Data
Estimated Reserves at SEC Pricing, page 31
1.After consideration of your response to prior comment number 3 and further review
of 2021 Activity on pages 35 to 36, the overall reconciliation of changes in proved
developed and proved undeveloped reserves does not appear to account for the 19.4 Bcfe
of proved undeveloped reserves converted to proved developed reserves disclosed on page
35. Please expand your narrative to identify where these converted volumes are included
in the reconciliation. Refer to the requirements in Item 1203 of Regulation S-K, FASB
ASC 932-235-50-5 description of proved reserves change categories, and Example 1 in
FASB ASC 932-235-55-2 for an illustration.
FirstName LastNameChristopher P. Kalnin
Comapany NameBKV Corporation
December 19, 2022 Page 2
FirstName LastName
Christopher P. Kalnin
BKV Corporation
December 19, 2022
Page 2
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
(202) 551-4727 with questions about engineering comments. Please contact Karina Dorin, Staff
Attorney, at (202) 551-3763 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Samantha Hal Crispin