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BKV Corporation

1200 17th Street, Suite 2100

Denver, CO 80202

June 26, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Loan Lauren Nguyen, Legal Branch Chief

    Liz Packebusch, Staff Attorney

    Karina Dorin, Staff Attorney

    Mark Wojciechowski, Staff Accountant

    Jenifer Gallagher, Staff Accountant

    Sandra Wall, Petroleum Engineer

 Re: BKV Corporation

Amendment No. 4 to Registration Statement on Form S-1

Filed April 14, 2023

File No. 333-268469

To the addressees set forth
above:

This letter sets forth the
responses of BKV Corporation (the “Company,” “we,” “our”
and “us”) to the comments set forth in the comment letter of the staff of the Securities and Exchange Commission
(the “Staff”) dated April 28, 2023 (the “Comment Letter”) relating to Amendment No.
4 to the Registration Statement on Form S-1, File No. 333-268469, filed with the Securities and Exchange Commission on April 14, 2023
(the “Registration Statement”). We have also revised the Registration Statement in response to the Staff’s
comments and, concurrently with delivery of this letter, we are publicly filing with the Securities and Exchange Commission an Amendment
No. 5 to the Registration Statement on Form S-1 (“Amendment No. 5”) that reflects these revisions and generally
updates certain information in the Registration Statement.

To assist your review, set
forth below in bold are the comments of the Staff contained in the Comment Letter and immediately below each comment is the response of
the Company with respect thereto or a statement identifying the location in Amendment No. 5 of the requested disclosure or revised disclosure.
Please note that all references to page numbers in our responses refer to the page numbers of the registration statement included in Amendment
No. 5. Capitalized terms used but not defined herein have the meanings ascribed to such terms in Amendment No. 5.

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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.

Response:
The Registration Statement has been revised as requested. Please see pages 36 and 198 of Amendment No. 5.

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.

Response:
The Registration Statement has been revised as requested. Please see page 183 of Amendment No. 5.

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.

Response:
The Registration Statement has been revised as requested. Please see pages 194-195 of Amendment No. 5.

* * *

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We appreciate your attention
to this matter and hope the foregoing answers are responsive to your comments. Please direct any questions or comments regarding this
correspondence to the undersigned or to our counsel, Samantha Crispin of Baker Botts L.L.P. at (214) 953-6497, Preston Bernhisel of the
same firm at (214) 953-6783 or Adorys Velazquez of the same firm at (212) 408-2523.

    Very truly yours,

    BKV Corporation

    By:
     /s/ Christopher P. Kalnin

    Name:
    Christopher P. Kalnin

    Title:

    Chief Executive Officer

 cc: Samantha Crispin, Baker Botts L.L.P.

Preston Bernhisel, Baker Botts L.L.P.

Adorys Velazquez, Baker Botts L.L.P.

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