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BKV Corporation

1200 17th Street, Suite 2100

Denver, CO 80202

August 28, 2024

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. 11 to Registration Statement on Form S-1

Filed August 13, 2024

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 (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) dated August 26, 2024 (the “Comment
Letter”) relating to Amendment No. 11 to the Registration Statement on Form S-1, File No. 333-268469, filed
with the Commission on August 13, 2024 (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 Commission
an Amendment No. 12 to the Registration Statement on Form S-1 (“Amendment No. 12”) that reflects
these revisions and generally updates certain information in the Registration Statement. In addition, concurrently with the delivery
of this letter, we are submitting a supplemental letter providing additional information (the “Supplemental Letter”)
pursuant to Rule 418(b) under the Securities Act of 1933, as amended (the “Securities Act”), and
Rule 12b-4 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), in response to
the Staff’s comments.

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. 12 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. 12. Capitalized terms used but not defined herein have the meanings ascribed to such terms in
Amendment No. 12.

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Amendment
No. 11 to Registration Statement on Form S-1

Summary Reserves, Production and Operating Data

Estimated Reserves at SEC Prices, page 34

 1. We have reviewed the information
                                            provided in response to prior comment number 5 and note the following:

 · On pages 36 and 190 of Amendment
                                            No. 11, you disclose the total 5-year capital budget for the development of your proved
                                            undeveloped reserves, as of December 31, 2023, was approximately $356.2 million; however, this
                                            total does not agree with the proved undeveloped 5-year CapEx as provided in your
                                            response. Please review and revise to resolve any inconsistencies.

 · On pages 36, 133, and 190
                                            of Amendment No. 11, you disclose your total 2024 budget, as of December 31, 2023,
                                            was approximately $73.0 million; however, this total does not agree with the
                                            total 2024 CapEx (proved undeveloped plus proved behind-pipe) as provided in your response. Please
                                            review and revise to resolve any inconsistencies.

Response: The Registration
Statement has been revised as requested. Please see pages 37, 70 and 192 of Amendment No. 12.

 2. Regarding the supplemental tabular
                                            information provided in response to prior comment number 5, please provide the following
                                            additional information:

 · Your average working interest
                                            in your Pennsylvania PUD locations;

 · The gross cost per well for
                                            your Pennsylvania PUD locations, and;

 · Confirm that the total proved
                                            undeveloped CapEx amounts provided for your Pennsylvania locations is correct.  In this
                                            regard, we note no CapEx amounts were included for the locations scheduled in years
                                            2025 and 2026.

Response: The Company acknowledges
the Staff’s comment and has provided an updated version of the supplemental tabular information in the Supplemental Letter. The
Registration Statement has also been revised to conform with the updated version of the supplemental tabular information included in
the Supplemental Letter. Please see pages 3, 155, 174, 182 and 184 of Amendment No. 12.

The Supplemental Letter is being provided
to the Staff by our counsel, under separate cover, pursuant to Rule 418 under the Securities Act and Rule 12b-4 under the Exchange
Act. In addition, under separate cover, our counsel has requested confidential treatment of the supplemental information pursuant to
the provisions of 17 C.F.R. § 200.83.

We hereby request that this supplemental
information be returned to us or destroyed upon completion of your review and that, pending its return or destruction, it be withheld
from release as it contains competitively sensitive business information of the Company. We are also requesting that the Freedom of Information
Act officer accord the supplemental information furnished in connection with this letter confidential treatment under the Commission’s
rules.

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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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