COMERICA INC — Director's Dealing 2004

Jul 20, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-07-16

Reporting Person: DINAPOLI J PHILIP (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-07-16	Common Stock	A	315	$56.39	Acquired	190057	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	50176	Indirect
Common Stock	5871	Indirect
Common Stock	64575	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Director Stock Option (right to buy)	$19.92	2005-05-19	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$29.08	2006-05-17	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$40.09	2007-05-16	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$65.13	2008-05-15	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$62.75	2009-05-21	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$44.13	2010-05-19	Common Stock (2000)	2000	Direct
Director Stock Option (right to buy)	$57.15	2011-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$64.5	2012-05-21	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$43.63	2013-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$53.87	2014-05-18	Common Stock (2500)	2500	Direct

Footnotes

F1: 170,288 shares are held in a revocable living trust for estate planning purposes and 15,241 are held in an individual retirement account.

F2: Includes stock units held pursuant to deferred director plans and shares purchased with reinvested dividends as of July 7, 2004.