COMERICA INC — Director's Dealing 2005

Feb 8, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-02-04

Reporting Person: BUTTIGIEG JOSEPH J III (Director, Vice Chairman / Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-02-04	Common Stock	M	18000	$25.42	Acquired	105070	Direct
2005-02-07	Common Stock	S	18000	$58.9	Disposed	87070	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2005-02-04	Employee Stock Option (right to buy)	$25.42	M	18000	Disposed	2006-04-14	Common Stock (18000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	879	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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 (40000)	40000	Direct
Employee Stock Option (right to buy)	$41.5	2010-03-17	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$63.2	2012-04-17	Common Stock (70000)	70000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (68000)	68000	Direct
Employee Stock Option (right to buy)	$52.5	2014-04-16	Common Stock (75000)	75000	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.