United States securities and exchange commission logo

                 May 24, 2021

       M. Jay Allison
       Chief Executive Officer
       Comstock Resources, Inc.
       5300 Town and Country Blvd., Suite 500
       Frisco, Texas 75034

                                                        Re: Comstock Resources,
Statement on Form S-3
                                                            Filed May 17, 2021
                                                            File No. 333-256221

       Dear Mr. Allison:

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

               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 Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 with any


                 Division of Corporation Finance

                 Office of Energy & Transportation
       cc:                                              Jack. G. Jacobsen, Esq.