United States securities and exchange commission logo October 29, 2020 Roland Burns President and Chief Financial Officer Comstock Resources, Inc. 5300 Town and Country Blvd. Suite 500 Frisco, Texas 75034 Re: Comstock Resources, Inc. Form 10-K for Fiscal Year Ended December 31, 2019 Filed March 2, 2020 File No. 1-03262 Dear Mr. Burns: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Brian Claunch