5300 Town and Country Blvd., Suite 500

Frisco, Texas 75034



April 21, 2020


U.S. Securities and Exchange Commission

100 F Street, NE, Mail Stop 3561

Washington, D.C. 20549

Attention: Ms. Karina Dorin



Comstock Resources, Inc.

Registration Statement on Form S-3

Filed April 14, 2020

File No. 333-237677



Dear Ms. Dorin:


Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Comstock Resources, Inc. (the “Registrant”) hereby requests acceleration of effectiveness of its Registration Statement on Form S-3 (File No. 333-237677), to April 24, 2020, at 9:00 a.m. Eastern Time, or as soon as possible thereafter.





Very truly yours,





/s/ Roland O. Burns


Roland O. Burns


President and Chief Financial Officer



Locke Lord LLP


Jack Jacobsen