COMERICA INC — Director's Dealing 2004

May 19, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-05-18

Reporting Person: PIERGALLINI ALFRED A (Director)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-05-18	Director Stock Option (right to buy)	$53.87	A	2500	Acquired	2014-05-18	Common Stock (2500)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	44557	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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)	$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

Footnotes

F1: Includes shares owned pursuant to deferred director plans and
purchased with reinvested dividends as of March 22, 2004.