This study explores significant eye-gaze features that can be used to estimate subjective difficulty while reading educational comics. Educational comics have grown rapidly as a promising way to teach difficult topics using illustrations and texts. However, comics include a variety of information on one page, so automatically detecting learners' states such as subjective difficulty is difficult with approaches such as system log-based detection, which is common in the Learning Analytics field. In order to solve this problem, this study focused on 28 eye-gaze features, including the proposal of three new features called “Variance in Gaze Convergence,” “Movement between Panels,” and “Movement between Tiles” to estimate two degrees of subjective difficulty. We then ran an experiment in a simulated environment using Virtual Reality (VR) to accurately collect gaze information. We extracted features in two unit levels, page- and panel-units, and evaluated the accuracy with each pattern in user-dependent and user-independent settings, respectively. Our proposed features achieved an average F1 classification-score of 0.721 and 0.742 in user-dependent and user-independent models at panel unit levels, respectively, trained by a Support Vector Machine (SVM).