COMERICA INC — Director's Dealing 2007

May 22, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-05-18

Reporting Person: GUMMER CHARLES L (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-05-18	Common Stock	S	200	$63.44	Disposed	81503	Direct
2007-05-18	Common Stock	S	800	$63.45	Disposed	80703	Direct
2007-05-18	Common Stock	S	700	$63.46	Disposed	80003	Direct
2007-05-18	Common Stock	S	700	$63.47	Disposed	79303	Direct
2007-05-18	Common Stock	S	1600	$63.48	Disposed	77703	Direct
2007-05-18	Common Stock	S	1000	$63.49	Disposed	76703	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1500	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (25000)	25000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (20500)	20500	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (25000)	25000	Direct

Footnotes

F1: Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and stock units held pursuant to a deferred compensation plan as of May 18, 2007.

F2: The options vest in four equal annual installments beginning on the date indicated in this column.