COMERICA INC — Director's Dealing 2007

Apr 20, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-04-20

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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-20	Common Stock	S	300	$63.54	Disposed	109143	Direct
2007-04-20	Common Stock	S	200	$63.43	Disposed	108943	Direct
2007-04-20	Common Stock	S	100	$63.39	Disposed	108843	Direct
2007-04-20	Common Stock	S	500	$63.38	Disposed	108343	Direct
2007-04-20	Common Stock	S	400	$63.37	Disposed	107943	Direct
2007-04-20	Common Stock	S	400	$63.35	Disposed	107543	Direct
2007-04-20	Common Stock	S	700	$63.34	Disposed	106843	Direct
2007-04-20	Common Stock	S	400	$63.33	Disposed	106443	Direct
2007-04-20	Common Stock	S	1100	$63.32	Disposed	105343	Direct
2007-04-20	Common Stock	S	200	$63.31	Disposed	105143	Direct
2007-04-20	Common Stock	S	400	$63.30	Disposed	104743	Direct
2007-04-20	Common Stock	S	600	$63.29	Disposed	104143	Direct
2007-04-20	Common Stock	S	900	$63.28	Disposed	103243	Direct
2007-04-20	Common Stock	S	100	$63.27	Disposed	103143	Direct
2007-04-20	Common Stock	S	700	$63.22	Disposed	102443	Direct

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 (40000)	40000	Direct
Employee Stock Option (right to buy)	$41.50	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)	$63.20	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)	$52.50	2014-04-16	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (50000)	50000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (50000)	50000	Direct

Footnotes

F1: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of April 20, 2007.

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