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CORRESP
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 O’Melveny
 & Myers LLP
 2801
 North Harwood Street
 Suite 1600
 Dallas, TX 75201-2692
 T:
 +1 972 360 1900
 F:
 +1 972 360 1901
 omm.com
 File
 Number: 0633831-00003

 August
18, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:
 Jenifer
 Gallagher
 Karl
 Hiller

 Re:
 Next
 Bridge Hydrocarbons, Inc.
 Form
 10-K for the Fiscal Year ended December 31, 2023
 Filed
 July 17, 2024
 Comment
 letter dated June 11, 2025
 File
 No. 000-56648

 Dear
Ms. Gallagher and Mr. Hiller:

 On
behalf of Next Bridge Hydrocarbons, Inc., a Nevada corporation (the “ Company ”), set forth below are the Company’s
responses to the letter dated June 11, 2025 setting forth the text of the comments of the staff (the “ Staff ”) of the
Securities and Exchange Commission (the “ Commission ”) on the Company’s above-referenced Annual Report on Form
10-K for the fiscal year ended December 31, 2023 filed on July 17, 2024 (the “ Annual Report ”). Capitalized terms used
but not otherwise defined in this letter have the meanings ascribed to them in the Annual Report.

 This
letter is being filed electronically via the EDGAR system today. Capitalized terms used but not otherwise defined in this letter have
the meanings set forth in the Annual Report.

 Exhibit
A – Draft Amendment to Form 10-K for the Fiscal Year ended December 31, 2023

 Explanatory
Note, page 1

 1. Please
include Part II - Item 9.A. Controls and Procedures in your list of items that will be revised in your amendment to the annual report.

 Response :
In response to the Staff’s comment, the Company has included the heading Part II - Item 9.A. Controls and Procedures under “Explanatory
Note” and the relevant disclosures in the draft amendment to the Annual Report on Form 10-K attached hereto as Exhibit A
(the “ Draft Amendment ”).

 Management’s
Discussion and Analysis of Financial Condition and Results of Operation Production Revenues and Cost of Revenues, page
18

 2. Please
remove the predecessor/successor presentation of the production and revenue detail for your Oklahoma properties for the fourth quarter.

 Response :
In response to the Staff’s comment, the Company has revised the disclosures to remove the predecessor and successor presentation
in the Draft Amendment.

 Austin
● Century City ● Dallas ● Houston ● Los Angeles ● Newport Beach ● New York ● San Francisco
● Silicon Valley ● Washington, DC

 Beijing
● Brussels ● Hong Kong ● London ● Seoul ● Shanghai ● Singapore ● Tokyo

 August
18, 2025

 Page
2

 Financial
Statements

 Report
of Independent Registered Public Accounting Firm, page F-1

 3. We
see that you have included a draft audit opinion along with your draft amendment, which appears to be incomplete not only with respect
to the date of issuance, but also the explanatory language regarding the restatement, and communication of critical audit matters pertaining
to the evaluation of capitalized oil and gas property costs for impairment under the full cost method, based on the requirements of PCAOB
AS 3101, paragraphs 18(e) and 11 through 14.

 Please
discuss these requirements with your auditors and confirm that such content will appear in the opinion that accompanies the amendment.
However, if this is not their intention, provide us with an explanation from the firm detailing how the aforementioned guidance was considered
in formulating their view.

 Response :
In response to the Staff's comment, the Company respectfully advises
the Staff that in light of the auditing review still in progress as of the date of the response letter submitted May 9, 2025, the Company's
independent auditors were not in a position to issue its revised opinion. The Company's prior submission of the draft Annual Report
on Form 10-K remained subject to completion of the audit. The new auditor report is included in the Draft Amendment beginning on page
F-1.

 Note
2 – Going Concern, page F-6

 4. Please
revise the second sentence of the first paragraph of this note to reference the correct restated net loss amount for the fiscal year
December 31, 2023.

 Response :
In response to the Staff's comment, the Company has revised the disclosures,
and directs the Staff to the updated disclosures in Note 4 of the Draft Amendment.

 Note
3 – Significant Accounting Policies

 Oil
and natural gas properties, page F-8

 5. Please
address the apparent inconsistency between your disclosure in the second paragraph on page F-8, stating that you recorded an impairment
of $28,192,277 related to properties other than the Orogrande Project in 2022, with details in the corresponding financial statements,
which do not identify this change.

 Response :
In response to the Staff's comment, the Company has revised the disclosures,
and directs the Staff to the updated disclosures in Note 5 of the Draft Amendment.

 Note
12 – Correction of Previously Issued 2023 Financial Statements, page F-19

 6. Based
on the content of this note, it appears that you should revise the header to clarify that it pertains to your 2022 rather than 2023 financial
statements.

 Response :
In response to the Staff’s comment, the Company has revised the header accordingly as reflected in Note 2 of the Draft
Amendment.

 August
18, 2025

 Page
3

 7. Please
expand your disclosure to include a description of the errors that have led to the restatement to comply with ASC 250-10-50-7, including
the errors in your initial accounting in the 2022 annual report, and the errors attendant to the restatements that were made to the 2022
annual amounts when filing your 2023 annual report, and to the 2023 first, second and third quarter interim amounts, in the comparative
presentations when filing the corresponding interim reports.

 For
example, it should be clear that your initial accounting for the oil and gas properties was incorrectly based on a presumption of fair
value and did not properly consider the continuity of the economic interests that had been conveyed via preferred shares issued by Torchlight
Energy Resources, Inc. to its common shareholders just prior to its reverse merger with Meta Materials Inc., and with regard to your
earlier restatement, it should be clear that the elimination of all value ascribed to the oil and gas properties was incorrectly based
on a presumption of impairment in the absence of having established oil and gas reserves and without having yet secured an extension
to the lease, and did not properly consider your stated intentions and rights to extend the lease coupled with your ongoing efforts to
evaluate the Orogrande properties in the application of the full cost method of accounting, particularly with regard to unevaluated property
costs. Please include a similar summary of these errors when reporting corrections to your 2024 interim reports.

 The
disclosures requested as outlined above should replace the language in the first paragraph in Note 12, which presently indicates that
your initial accounting for the oil and gas properties at December 31, 2022 was to recognize a full impairment based on a December 14,
2022 determination of the properties having no value. Please also expand the tabulations to include additional columns with the originally
reported amounts for 2022 and the adjustments that were made in your initial restatement, and provide the narratives that are necessary
to correlate with the summary of accounting errors provided in response to the preceding paragraph.

 Any
references to the error corrections as adjustments to modify comparative amounts or to modify the accounting treatment should also be
revised to more clearly align with and reflect their instrumentality in providing financial statements that comply with generally accepted
accounting principles. This point also applies to the error correction disclosures that you intend to include in your 2024 annual report.

 Response :
In response to the Staff’s comment, the Company has revised the relevant disclosures as reflected in the Draft Amendment.

 8. We
suggest that you remove the table on page F-19 detailing the original values assigned to the assets and liabilities received in the spin
off, unless you are intending to augment the table to include columns for revisions and the restated balances as of that interim date,
or to otherwise establish its relevance in the restatement effort.

 Response :
In response to the Staff’s comment, the Company has revised the relevant disclosures as reflected in the Draft Amendment.

 9. Given
your plans to restate your 2022 annual and 2023 interim financial statements, it appears that you are delinquent in filing an Item 4.02
Form 8-K, which was required to be filed within four business days of having concluded that previously issued financial statements should
no longer be relied upon because of an error. Please comply with your reporting obligations under Rule 13a-11 of Regulation 13A.

 Response :
In response to the Staff’s comment, the Company respectfully advises the Staff that the Company’s Current Report on Form
8-K was filed with the Commission on June 24, 2025.

 10. We
note that you provided a notice of late filing for your 2024 annual report on March 31, 2025, which includes a brief description of the
pending restatement that indicates it pertains to a prior restatement “related to the timing of impairment adjustments” that
were previously recorded in 2022 but will be recorded in 2024 instead. You further state that the adjustment for 2024 will approximate
$73 million and that such impairment “had been previously addressed in prior year filings.”

 However,
the reasons cited in your correspondence during our review for your mid-2024 restatement of the 2022 annual amounts and the 2023 interim
amounts reflected an incorrect application of the full cost method of accounting for oil and gas activities, and did not encompass the
October 8, 2024 decision by University Lands to not extend your Development Unit Agreement for the Orogrande asset, nor its effort to
immediately terminate the agreement. This is evident in the interim report that you filed on August 14, 2024, which followed the earlier
restatement and preceded the University Lands announcement. You indicated that you had until the end of the year to complete your drilling
commitments and stated that the DDU Agreement “...grants the right to extend the DDU Agreement through December 31, 2028 if compliance
with the DDU Agreement is met...” and the company “expects to exercise its option to extend the term under the DDU Agreement
prior to its expiration.”

 August
 18, 2025

 Page
4

 Given
that the circumstances have changed, your disclosures regarding the corrections necessary to effect the current restatement should not
indicate that you are simply repositioning an impairment that you had previously recognized or addressed, and should clearly distinguish
between those earlier circumstances and the circumstances that arose in connection with that decision by University Lands, which appears
to preclude any further involvement with the properties. Please ensure that disclosures pertaining to the upcoming impairment charge
conform with this guidance.

 Response :
In response to the Staff’s comment, the Company respectfully advises the Staff that the relevant disclosures pertaining to the
impairment charge will conform to the Staff’s guidance in the 2024 Annual Report on Form 10-K when filed.

 Note
14 – Explanation of Quarterly Impact, page F-26

 11. We
note that you have utilized a mixed and incomplete approach in presenting the corrections impacting the 2023 interim financial statements.
For example, some amounts were as originally reported while others were previously restated, being sourced from the original report for
the first quarter, a Form S-1/A for the second quarter, and an interim report from the following year for the third quarter.

 The
restated interim financial information on pages F-27 through F-35 should be revised to include additional columns of information on each
tabulation to present the originally reported amounts for each quarter of 2023, the revisions made in connection with your earlier restatement,
the earlier restatement amounts, the revisions that are being made in the current restatement, and the current restatement amounts. The
disclosures pertaining to error corrections impacting activity from the statements of operations and cash flows for the second and third
quarters of 2023 should also include a set of tabulations that cover activity of these particular quarters (in addition to the cumulative
interim amounts presently shown).

 Please
expand the summary tabulations on page F-26 to include three columns for each period, having the originally reported amounts, the previously
restated amounts, and the currently restated amounts (to include amounts for each quarter in addition to the cumulative amounts reported
for the second and third quarters), and specify the dates of initially filing the original interim reports and the dates of initially
filing the earlier restatements for each period covered by those reports.

 Response :
In response to the Staff’s comment, the Company has revised the presentation of the restated interim financial information as reflected
in Note 3 of the Draft Amendment.

 12. Please
expand your disclosures pertaining to the restatement items for each interim period of 2023 to include a brief description of the transactions
or activities associated with the costs that had been incurred during the quarter that were initially capitalized pursuant to Rule 4-10(c)(2)
of Regulation S-X, and that were incorrectly written-off in connection with your earlier restatement, and that are being restored in
your current restatement to comply with the full cost method.

 Response :
In response to the Staff’s comment, the Company has revised the relevant disclosures as reflected in the Draft Amendment.

 August
18, 2025

 Page
5

 Exhibit
B – Draft Explanation of Corrections, page F-36

 13. We
note that your summary table having the “As Reported” and “As Restated” columns for each of the first three quarters
of 2024 reflects on the activity line items cumulative interim period amounts for the second and third quarters, rather activity that
is specific and limited to these quarters.

 Please
expand the summary table to also cover activity for the second and third quarters alone; and provide tabulations with the activity from
your statements of operations and cash flows for the second and third quarters alone (including the originally reported amounts, adjustments,
and restated amounts), adjacent to the tabulations covering the corresponding cumulative interim periods.

 Please
modify the main header of each tabulation to specify the date or period to which the information pertains, and eliminate other dates
from the sub-column headers. The introductory remarks to the restatement disclosures should clarify the dates that periodic reports for
which financial information is being restated were originally filed, rather than in the column headers.

 Response :
In response to the Staff’s comment, the Company has revised the presentation of the unaudited restated interim financials to be
set forth in the Annual Report on Form 10-K for the year ended December 31, 2024, as reflected on Exhibit B attached to this letter
(the “ 2024 Draft Corrections ”).

 14. We
note that your draft revisions for the statements of cash flows, covering the three months March 31, 2024 and six months June 30, 2024,
reflect in the restated columns as an investing activity $1,141,142 of proceeds from the sale of assets, which had originally been misreported
as a financing activity. In your November 13, 2024 response to comment 3 of our letter dated October 31, 2024, you agreed to correct
this error. However, the corrections do not appear as adjustments