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COMERICA INC Director's Dealing 2005

May 6, 2005

30676_dirs_2005-05-06_1b83b0ea-01bf-42ad-82e5-8c45649dfeaf.zip

Director's Dealing

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SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-05-05

Reporting Person: BAUDER LILLIAN (Director)

Non-Derivative Transactions

Date Security Code Shares Price A/D Holdings After Ownership
2005-05-05 Common Stock J 93 Acquired 11690 Direct

Holdings (Derivative)

Security Exercise Price Expiration Underlying Shares Ownership
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) $64.50 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
Restricted Stock Units $0 1988-08-08 Common Stock (319) 319 Direct

Footnotes

F1: The shares were acquired by reporting person in connection with a distribution from one of Issuer's director deferral plans on May 5, 2005.

F2: The shares that were acquired by reporting person in connection with this transaction have been included in Table I of previous filings, and accordingly, this transaction does not vary the amount of securities beneficially owned by reporting person.

F3: Includes stock units held pursuant to deferred director plans and shares purchased with reinvested dividends as of May 5, 2005.

F4: The restricted stock units vest one year after the date of grant. Vested shares are settled one year after the insider's date of retirement.

F5: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.