COMERICA INC — Director's Dealing 2004

Jan 20, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-01-16

Reporting Person: MOORADIAN DENNIS J (Exec. VP, Wealth & Inst. Mgt.)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-01-16	Common Stock	J	41	$56.76	Acquired	35514	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.9	2013-11-04	Common Stock (60000)	60000	Direct

Footnotes

F1: Matching contribution by the issuer made pursuant to the Employee Stock Purchase Plan.

F2: This number includes shares acquired through employee stock plans.

F3: The option vests in four equal annual installments beginning on the date indicated in this column.