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                               September 18, 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
                                                            Form 8-K Filed
August 5, 2020
                                                            File No. 1-03262

       Dear Mr. Burns:

              We have reviewed your filings and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2019

       Business and Properties
       Primary Operating Areas, page 9

   1.                                                   Expand your disclosure
to provide the annual volumes of production by final product sold
                                                        for each of the last
three fiscal years, including the disclosure of natural gas liquids
                                                        production if sold
separately. Refer to the disclosure requirements in Item 1204(a) of
                                                        Regulation S-K.
       Oil and Natural Gas Reserves, page 11

   2.                                                   The third party
reserves audit reports filed as Exhibits 99.1 and 99.2, respectively, disclose
                                                        natural gas liquids
reserves; however, such reserves are not disclosed in the filing on Form
 Roland Burns
Comstock Resources, Inc.
September 18, 2020
Page 2
         10-K as of December 31, 2019. Tell us the reason(s) for this apparent
inconsistency in the
         disclosure of your proved reserves.
3.       The tabular presentation provided on page 11 relating to the proved
reserves as of
         December 31, 2019 indicates that the present worth discounted at 10% (
  PV 10 Value   )
         for your proved developed non-producing reserves is positive. However,
both third party
         reserves audit reports filed as Exhibits 99.1 and 99.2, respectively,
disclose that the
         present worth at 10% relating to such reserves is negative. Tell us
the reason(s) for this
         apparent inconsistency in the disclosure of information relating to
your proved reserves.
4.       The third party reserves audit report filed as Exhibit 99.2 indicates
that you have included
         estimates of proved undeveloped reserves for certain locations that
generate positive
         future net revenue but have negative present worth discounted at 10
percent. Tell us if the
         referenced locations were part of the development plan adopted by your
management at
         December 31, 2019. Refer to Rule 4-10(a)(31)(ii) of Regulation S-X.
5.       If you have adopted a plan to drill proved undeveloped locations with
negative present
         worth discounted at 10 percent, disclose the marginal nature of these
wells and the
         economic risk that they pose in your filing. Refer to FASB ASC
932-235-50-10 and your
         response dated January 19, 2012 to comment 3 in the letter dated
December 28, 2011.
6.       Revise the tabular disclosure provided on page 12 relating to the
average production cost
         per unit of production for each of the last three fiscal years to
exclude the costs relating to
         severance and ad valorem taxes and transportation costs. Refer to Item
1204(b)(2) of
         Regulation S-K.
7.       The tabular reconciliation of the changes that occurred in proved
undeveloped reserves
         provided on page 13 indicates that no new reserves were added from
extensions and
         discoveries for the fiscal year ended December 31, 2019. This
disclosure appears to be
         inconsistent with the level of drilling activity that occurred during
the year and the
         disclosure relating to the change in total proved reserves for new
reserves added from
         extension and discoveries. Tell us the reason(s) for this apparent
inconsistency in the
         disclosure of information relating to your proved undeveloped
reserves.
Exhibits and Financial Statement Schedules
(b) Exhibits
Exhibit 99.1, page 66

8.     Expand the disclosure in Exhibit 99.1 to provide the qualifications of
the technical
       person(s) of the independent petroleum engineering firm primarily
responsible for
FirstName LastNameRoland Burns
       overseeing the firm   s audit of the Company   s proved reserves.
Alternatively, expand the
Comapany    NameComstock
       disclosure             Resources,
                  in the filing          Inc. to provide this disclosure. Refer
to the disclosure
                                on Form 10-K
       requirements
September            pursuant
           18, 2020 Page    2 to Item 1202(a)(7) of Regulation S-K.
FirstName LastName
 Roland Burns
FirstName LastNameRoland   Burns
Comstock Resources, Inc.
Comapany 18,
September NameComstock
              2020        Resources, Inc.
September
Page 3    18, 2020 Page 3
FirstName LastName
9.       The disclosure in Exhibit 99.1 does not appear to address all of the
requirements of the
         report pursuant to Item 1202(a)(8) of Regulation S-K. Obtain and file
a revised reserves
         report to address the following points:

                The reserves report should state the purpose for which the
report was prepared, e.g.
              for inclusion as an exhibit in a filing made with the U.S.
Securities and Exchange
              Commission. See Item 1202(a)(8)(i) of Regulation S-K.

                The reserves report should specify the initial benchmark and
the average realized
              prices after adjustments for location and quality differentials,
by product type,
              including natural gas liquids, for the reserves included in the
report. See Item
              1202(a)(8)(v) of Regulation S-K.
10.      The reserves report refers to additional supplemental information,
e.g. various summaries
         including Schedule No. 1 through Schedule No. 5 and an Appendix: SEC
Petroleum
         Reserve Definitions that are not included with the report. Obtain and
file a revised report
         to include the referenced supplemental information. Alternatively,
remove these
         references if you do not intend to include this supplemental
information.
11.      The tabular summary of the estimated remaining net reserves and future
net revenue
         provided on page 1 indicates that the proved developed non-producing
reserves have
         negative future net revenue, both undiscounted and discounted at 10%.
Tell us why these
         reserves meet the requirements to be classified as proved reserves at
December 31, 2019.
         Refer to the definitions of economically producible, proved reserves,
and reserves in
         Rules 4-10(a)(10), (a)(22) and (a)(26) of Regulation S-X,
respectively.
Notes to Consolidated Financial Statements
Note 14 Oil and Gas Reserves Information (Unaudited), page F-36

12.      Expand your disclosure of the changes in the net quantities of total
proved reserves for
         each of the periods presented to include an appropriate narrative
explanation of the
         significant changes related to each line item other than production.
To the extent that two
         or more separate and unrelated factors are combined to arrive at the
line item figure, your
         disclosure should separately identify and quantify each individual
factor that contributed
         to a significant change so that the change in net reserves between
periods is fully
         explained. In particular, disclosure relating to the revisions in
previous estimates of
         reserves should identify such underlying factors as changes caused by
commodity prices,
         well performance, improved recovery, uneconomic proved undeveloped
locations or
         changes resulting from the removal of proved undeveloped locations due
to changes in a
         previously adopted development plan. Refer to FASB ASC 932-235-50-5
and Instruction
         1 to Item 302(b) of Regulation S-K.
13.      The figures relating to the changes that occurred in your total proved
reserves due to
         extensions and discoveries appear to be inconsistent with the
corresponding figures
         relating to such changes that occurred in your proved undeveloped
reserves for each of the
 Roland Burns
Comstock Resources, Inc.
September 18, 2020
Page 4
      last three fiscal years presented. Expand the discussion of the changes
in your total
      proved reserves attributed to extensions and discoveries to explain the
reason(s) for this
      difference. Refer to FASB ASC 932-235-50-5.
14.   Tell us if the costs associated with the abandonment of your proved
undeveloped
      locations, have been included as part of the future development costs
used in the
      calculation of the standardized measure as of December 31, 2019. If such
costs have been
      omitted, explain to us your basis for excluding these costs from your
calculation of the
      standardized measure.
Form 8-K Filed August 5, 2020

Exhibit 99.1
Financial Results for the Three and Six Months Ended June 30, 2020, page 1

15.   We note your presentation of the non-GAAP measure adjusted net income
available to
      common stockholders. Revise to present a tabular reconciliation of
adjusted net income
      available to common stockholders to net income. Additionally, revise to
disclose the
      reasons why you believe your presentation of this non-GAAP measure
provides useful
      information to investors. Lastly, revise to disclose the purposes for
which management
      uses this non-GAAP measure. Please refer to Regulation G and Item
10(e)(1)(i) of
      Regulation S-K.
16.   We note certain line items in your tabular reconciliation of net income
to EBITDAX that
      are not traditionally included to arrive at the non-GAAP measure EBITDAX.
Tell us
      whether you considered labeling this measure adjusted EBITDAX.
        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.

        You may contact Yolanda Guobadia, Staff Accountant, at (202) 551-3562
or Robert
Babula, Staff Accountant, at (202) 551-3339 if you have questions regarding
comments on the
financial statements and related matters. Please contact John Hodgin, Petroleum
Engineer, at
(202) 551-3699 with any other questions.



                                                            Sincerely,
FirstName LastNameRoland Burns
                                                            Division of
Corporation Finance
Comapany NameComstock Resources, Inc.
                                                            Office of Energy &
Transportation
September 18, 2020 Page 4
cc:       Brian Claunch
FirstName LastName