August 26, 2024

Christopher P. Kalnin
Chief Executive Officer
BKV Corporation
1200 17th Street, Suite 2100
Denver, CO 80202

       Re: BKV Corporation
           Amendment No. 11 to Registration Statement on Form S-1
           Filed August 13, 2024
           File No. 333-268469
Dear Christopher P. Kalnin:

     We have reviewed your amended registration statement and have the
following
comment(s).

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we
note otherwise,
any references to prior comments are to comments in our July 29, 2024 letter.

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.
 August 26, 2024
Page 2

             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.
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.

        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