August 5, 2019 M. Jay Allison Chief Executive Officer COMSTOCK RESOURCES INC 5300 Town and Country Blvd., Suite 500 Frisco, Texas 75034 Re: COMSTOCK RESOURCES INC Registration Statement on Form S-3 Filed July 31, 2019 File No. 333-232924 Dear Mr. Allison: This is to advise you that we have not reviewed and will not review your registration statement. 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 Kevin Dougherty at (202) 551-3271 with any questions. Sincerely, Division of Corporation Finance Office of Natural Resources cc: Jack E. Jacobsen