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April 28, 2023
Christopher P. Kalnin
Chief Executive Officer
BKV Corporation
1200 17th Street, Suite 2100
Denver, CO 80202
Re:BKV Corporation
Amendment No. 4 to Registration Statement on Form S-1
Filed April 14, 2023
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.
Amendment No. 4 to Registration Statement on Form S-1
Summary Reserve, Production and Operating Data
2022 Activity, page 35
1.Your filing states on pages 35 and 188 that during 2022, “Revisions of previous estimates
consisted of upward revisions to proved developed reserves and proved undeveloped
reserves of 182.9 Bcfe as a result of higher average pricing during 2022 for natural gas,
NGLs and oil.” However, on page F-50, this upward pricing revision of 182.9 Bcfe is
attributed solely to proved developed reserves. Please review and revise your filing so that
all volume changes are consistent and correlate with the reconciliations provided.

 FirstName LastNameChristopher P. Kalnin
 Comapany NameBKV Corporation
 April 28, 2023 Page 2
 FirstName LastName
Christopher P. Kalnin
BKV Corporation
April 28, 2023
Page 2
Our Operations
Drilling, Refrac and Restimulation Activity, page 174
2.Please expand your filing to include a description of your present activities, including the
number of gross and net wells in process, as of December 31, 2022. Refer to the
disclosure requirements in Item 1206 of Regulation S-K.
Summary of Our Reserve Estimates
Estimated Reserves at SEC Pricing, page 184
3.Your presentation of estimated probable and possible reserves at SEC pricing on pages
185-186 includes multiple lines labeled as “Total estimated proved undeveloped reserves
(MMcfe)”, which, in fact, appear to refer to probable and possible developed and
undeveloped reserves.  Please review and revise the labels in this presentation as
necessary to resolve these inconsistencies.
            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 Liz Packebusch,
Staff Attorney, at (202) 551-8749 or Karina Dorin, Staff Attorney, at (202) 551-3763 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Samantha Hale Crispin