COMERICA INC — Director's Dealing 2005

Feb 25, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-02-23

Reporting Person: GUMMER CHARLES L (Pres/CEO-Comerica Bank-Tex Div)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-02-23	Common Stock	M	6500	$18.59	Acquired	74460	Direct
2005-02-24	Common Stock	S	1300	$57.06	Disposed	73160	Direct
2005-02-24	Common Stock	S	600	$57.07	Disposed	72560	Direct
2005-02-24	Common Stock	S	200	$57.08	Disposed	72360	Direct
2005-02-24	Common Stock	S	1400	$57.09	Disposed	70960	Direct
2005-02-24	Common Stock	S	1800	$57.10	Disposed	69160	Direct
2005-02-24	Common Stock	S	1200	$57.11	Disposed	67960	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2005-02-23	Employee Stock Option (right to buy)	$18.59	M	6500	Disposed	2005-04-18	Common Stock (6500)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1500	Indirect
Common Stock	5024	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$25.42	2006-04-14	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$40.25	2007-04-20	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (25000)	25000	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (25000)	25000	Direct
Employee Stock Option (right to buy)	$41.50	2010-03-17	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (15800)	15800	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (24800)	24800	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (24500)	24500	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (25000)	25000	Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of January 30, 2005.

F2: As of January 30, 2005.

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