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: 2007-04-19

Reporting Person: Ogden Thomas D (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-19	Common Stock	S	1000	$63.14	Disposed	20455	Direct
2007-04-19	Common Stock	S	2000	$63.13	Disposed	18455	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	3485	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (Right to Buy)	$71.58	2008-03-20	Common Stock (6375)	6375	Direct
Employee Stock Option (Right to Buy)	$66.81	2009-03-19	Common Stock (7350)	7350	Direct
Employee Stock Option (Right to Buy)	$41.50	2010-03-17	Common Stock (8000)	8000	Direct
Employee Stock Option (Right to Buy)	$51.43	2011-05-02	Common Stock (6600)	6600	Direct
Employee Stock Option (Right to Buy)	$63.20	2012-04-17	Common Stock (12000)	12000	Direct
Employee Stock Option (Right to Buy)	$40.32	2013-04-17	Common Stock (11900)	11900	Direct
Employee Stock Option (Right to Buy)	$52.50	2014-04-16	Common Stock (8500)	8500	Direct
Employee Stock Option (Right to Buy)	$54.99	2015-04-21	Common Stock (12000)	12000	Direct
Employee Stock Option (Right to Buy)	$56.47	2016-02-15	Common Stock (10600)	10600	Direct
Employee Stock Option (Right to Buy)	$58.98	2017-01-23	Common Stock (12000)	12000	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 April 19, 2007.

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