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COMERICA INC Director's Dealing 2007

May 9, 2007

30676_dirs_2007-05-09_c449d892-7dbf-4555-97b2-1151242bd760.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: 2007-05-08

Reporting Person: CUMMINGS PETER D (Director)

Non-Derivative Transactions

Date Security Code Shares Price A/D Holdings After Ownership
2007-05-08 Common Stock M 1500 $40.09 Acquired 13072 Direct

Derivative Transactions

Date Security Exercise Price Code Shares A/D Expiration Underlying Ownership
2007-05-08 Director Stock Option (right to buy) $40.09 M 1500 Disposed 2007-05-16 Common Stock (1500) Direct

Holdings (Non-Derivative)

Security Shares Ownership
Common Stock 3816 Indirect

Holdings (Derivative)

Security Exercise Price Expiration Underlying Shares Ownership
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: Includes stock units held pursuant to deferred director plans, restricted stock units, and shares purchased with reinvested dividends as of May 8, 2007.

F2: The reporting person disclaims beneficial ownership of these shares, and this report shall not be deemed an admission that the reporting person is the beneficial owner of these shares for purposes of Section 16 or for any other purpose.

F3: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F4: The restricted stock units vest one year after the date of grant. Vested shares are settled one year after cessation of service on the board.