Comstock Resources CRK Ratings Placed On CreditWatch Positive On Debt Refinancing On April 2, 2018, Comstock Resources announced a series of related transactions, including a proposed offering of new senior unsecured notes, in support of a comprehensive refinancing of substantially all of its existing debt. • We are placing our ratings on Comstock, including our 'CCC+' corporate credit rating, on CreditWatch with positive implications. • We expect to resolve the CreditWatch placement around the time the proposed new senior unsecured notes launch, which we expect by May 2018.

1. Research Update:
Comstock Resources Inc. Ratings
Placed On CreditWatch Positive On
Debt Refinancing Transactions
Primary Credit Analyst:
Aaron McLean, New York (1) 212-438-7211; aaron.mclean@spglobal.com
Secondary Contact:
Ben B Tsocanos, New York (1) 212-438-5014; ben.tsocanos@spglobal.com
Table Of Contents
Overview
Rating Action
Rationale
CreditWatch
Related Criteria
Ratings List
WWW.STANDARDANDPOORS.COM/RATINGSDIRECT APRIL 3, 2018 1

2. Research Update:
Comstock Resources Inc. Ratings Placed On
CreditWatch Positive On Debt Refinancing
Transactions
Overview
• On April 2, 2018, Comstock Resources announced a series of related
transactions, including a proposed offering of new senior unsecured
notes, in support of a comprehensive refinancing of substantially all of
its existing debt.
• We are placing our ratings on Comstock, including our 'CCC+' corporate
credit rating, on CreditWatch with positive implications.
• We expect to resolve the CreditWatch placement around the time the
proposed new senior unsecured notes launch, which we expect by May 2018.
Rating Action
On April 3, 2018, S&P Global Ratings placed its ratings, including its 'CCC+'
corporate credit rating, on U.S.-based oil and gas exploration and production
(E&P) company Comstock Resources Inc. on CreditWatch with positive
implications.
At the same time we placed the 'CCC+' issue-level rating on the company's 10%
first-lien secured toggle notes and 'CCC-' issue-level ratings on its 7.75%
and 9.50% second-lien convertible payment-in-kind (PIK) notes on CreditWatch
with positive implications. The recovery rating on the 10% first-lien secured
toggle notes is '3', reflecting our expectation of meaningful (50% to 70%;
rounded estimate: 55%) recovery in the event of default and '6' on the 7.75%
and 9.50% second-lien convertible PIK notes, reflecting our expectations of
negligible (0% to 10%; rounded estimate: 0%) recovery in the event of default.
We also placed the 'CCC-' issue-level rating on the company's remaining
outstanding 10% senior secured notes and 7.75% and 9.50% senior unsecured
notes on CreditWatch with positive implications. The recovery rating on all
three issues is '6', reflecting our expectations of negligible (0% to 10%;
rounded estimate: 0%) recovery in the event of default.
Rationale
The CreditWatch placement on Comstock reflects the likelihood for an upgrade
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3. following the completion of a series of related transactions aimed at
refinancing the company's existing debt. We expect the transactions to improve
the company's leverage and liquidity, and extend its debt maturities.
The proposed transactions include a $75 million equity investment from Arkoma
Drilling L.P. (not rated), the monetization of the company's Eagle Ford shale
assets, the arrangement of a new $300 million reserve-based credit facility,
tender offers for the second-lien convertible PIK notes at par for a package
of cash and equity, a tender offer for the company's first-lien secured toggle
notes at approximately 105.25% for cash, and the proposed issuance of
approximately $600 million of new unsecured notes.
All of the transactions, except the monetization of the Eagle Ford assets, are
dependent on the issuance of the new unsecured notes and will close
simultaneously upon completion of the offering. We expect the launch of the
new unsecured notes sometime in April 2018 pending market conditions.
CreditWatch
We would expect to raise Comstock's rating only if all the transactions are
completed as proposed. We will resolve the CreditWatch listing around the
launch of the new unsecured notes, which we expect to occur by the end April
2018.
Related Criteria
• Criteria - Corporates - General: Recovery Rating Criteria For
Speculative-Grade Corporate Issuers, Dec. 7, 2016
• Criteria - Corporates - General: Methodology And Assumptions: Liquidity
Descriptors For Global Corporate Issuers, Dec. 16, 2014
• Criteria - Corporates - Industrials: Key Credit Factors For The Oil And
Gas Exploration And Production Industry, Dec. 12, 2013
• Criteria - Corporates - General: Corporate Methodology: Ratios And
Adjustments, Nov. 19, 2013
• Criteria - Corporates - General: Corporate Methodology, Nov. 19, 2013
• General Criteria: Country Risk Assessment Methodology And Assumptions,
Nov. 19, 2013
• General Criteria: Methodology: Industry Risk, Nov. 19, 2013
• General Criteria: Methodology For Crude Oil And Natural Gas Price
Assumptions For Corporates And Sovereigns, Nov. 19, 2013
• General Criteria: Group Rating Methodology, Nov. 19, 2013
• General Criteria: Methodology: Management And Governance Credit Factors
For Corporate Entities And Insurers, Nov. 13, 2012
• General Criteria: Criteria For Assigning 'CCC+', 'CCC', 'CCC-', And 'CC'
WWW.STANDARDANDPOORS.COM/RATINGSDIRECT APRIL 3, 2018 3
Research Update: Comstock Resources Inc. Ratings Placed On CreditWatch Positive On Debt Refinancing
Transactions

4. Ratings, Oct. 1, 2012
• Criteria - Corporates - Industrials: Revised Assumptions For Assigning
Recovery Ratings To The Debt Of Oil And Gas Exploration And Production
Companies, Sept. 14, 2012
• General Criteria: Use Of CreditWatch And Outlooks, Sept. 14, 2009
Ratings List
Ratings Affirmed; CreditWatch Action
To From
Comstock Resources Inc.
Corporate Credit Rating CCC+/Watch Pos/-- CCC+/Negative/--
Ratings Affirmed; CreditWatch Action
To From
Comstock Resources Inc.
Senior Secured
US$697.195 mil 10.00% toggle nts due CCC+ /Watch Pos CCC+
2020
Recovery Rating 3(55%) 3(55%)
US$169.747 mil 9.50% 2nd lien PIK CCC- /Watch Pos CCC-
nts Convertible due 2020
Recovery Rating 6(0%) 6(0%)
US$270.557 mil 7.75% 2nd lien PIK CCC- /Watch Pos CCC-
nts Convertible due 2019
Recovery Rating 6(0%) 6(0%)
US$700 mil 10.00% nts due 03/15/2020 CCC- /Watch Pos CCC-
Recovery Rating 6(0%) 6(0%)
Senior Unsecured
US$300 mil 9.50% sr nts due CCC- /Watch Pos CCC-
06/15/2020
Recovery Rating 6(0%) 6(0%)
US$400 mil 7.75% sr unsecd nts due CCC- /Watch Pos CCC-
04/01/2019
Recovery Rating 6(0%) 6(0%)
Certain terms used in this report, particularly certain adjectives used to
express our view on rating relevant factors, have specific meanings ascribed
to them in our criteria, and should therefore be read in conjunction with such
criteria. Please see Ratings Criteria at www.standardandpoors.com for further
information. Complete ratings information is available to subscribers of
RatingsDirect at www.capitaliq.com. All ratings affected by this rating action
can be found on the S&P Global Ratings' public website at
www.standardandpoors.com. Use the Ratings search box located in the left
column.
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Research Update: Comstock Resources Inc. Ratings Placed On CreditWatch Positive On Debt Refinancing
Transactions

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