News Releases

Baker Botts Advises SOCAR on $1.65 Billion Investment in Comstock's Haynesville Assets and Midstream Infrastructure

Release

HOUSTON, September 1, 2026 – Baker Botts L.L.P., a leading international energy, technology, and life sciences law firm, is advising the State Oil Company of the Azerbaijan Republic ("SOCAR") in connection with a $1.65 billion strategic investment in Haynesville shale assets and related midstream infrastructure owned by Comstock Resources, Inc. (NYSE and NYSE Texas: CRK).

The transaction would establish SOCAR’s participation across Comstock’s upstream and midstream operations in the Haynesville region, one of North America’s key natural gas basins. The proposed investment would include a 20% non-operated interest in Comstock’s interest in its Legacy Haynesville assets, a 15% non-operated interest in Comstock’s interest in its Western Haynesville assets and a 15% interest in Comstock’s interest in Pinnacle Gas Services LLC, which provides midstream services supporting development in the region.

“We are proud to advise SOCAR on its first major oil and gas investment in the United States,” said Head of Project Finance, Nabil Khodadad. “This is a significant milestone for SOCAR’s growing international presence and shows the reach and depth of the Firm’s global energy platform.”

SOCAR and Comstock signed a letter of intent on Aug. 31, 2026, that binds the parties to negotiate in good faith toward a definitive purchase and sale agreement, which they expect to enter into by Oct. 31, 2026 with a targeted closing by the end of 2026. Closing is subject to customary closing conditions, including any required governmental and third-party approvals.

Baker Botts Lawyers/Offices Involved:

Global Projects: Nabil Khodadad (Partner, London); Cody Carper (Partner, Houston); Alia Heintz (Partner, Houston); Anna Irion (Partner, Houston); Nadine Amr (Partner, London); Jonice Cline (Special Counsel, Houston); Megan Young (Senior Associate, Houston); Lucy Shoemaker (Associate, Houston); Haekyong Min (Associate, Houston); Paige Meredith (Associate, Houston); Paul Magee (Associate, Houston); Abby Kite (Associate, Houston)

Litigation: Louie Layrisson (Partner, Houston)

Tax: Jon Lobb (Partner, Houston); Jordan Hahn (Partner, Dallas)

Environmental, Safety, and Incident Response: Elizabeth Singleton (Special Counsel, Houston)

Regulatory: Ryan Norfolk (Partner, Washington, D.C.); Michael Bodosky (Special Counsel, Washington, D.C.)

International Trade: Paul Luther (Partner, Washington, D.C.); Alexander Reinert (Associate, Washington, D.C.)

ABOUT BAKER BOTTS L.L.P.
Baker Botts is an international law firm whose lawyers practice throughout a network of offices around the globe. Based on our experience and knowledge of our clients' industries, we are recognized as a leading firm in the energy, technology and life sciences sectors. Since 1840, we have provided creative and effective legal solutions for our clients while demonstrating an unrelenting commitment to excellence. For more information, please visit bakerbotts.com.

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