April 17, 2020

M. Jay Allison
Chairman of the Board and Chief Executive Officer
Comstock Resources, Inc.
5300 Town and Country Blvd., Suite 500
Frisco, TX 75034

       Re: Comstock Resources, Inc.
           Registration Statement on Form S-3
           Filed April 14, 2020
           File No. 333-237677

Dear Mr. Allison:

       This is to advise you that we have not reviewed and will not review your

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 with any


                                                            Division of
Corporation Finance
                                                            Office of Energy &
cc:    Jack E. Jacobsen