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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-19	Common Stock	S	180	$62.78	Disposed	121143	Direct
2007-04-19	Common Stock	S	100	$62.72	Disposed	121043	Direct
2007-04-19	Common Stock	S	200	$62.66	Disposed	120843	Direct
2007-04-19	Common Stock	S	200	$62.58	Disposed	120643	Direct
2007-04-19	Common Stock	S	100	$62.59	Disposed	120543	Direct
2007-04-19	Common Stock	S	400	$62.56	Disposed	120143	Direct
2007-04-19	Common Stock	S	100	$62.53	Disposed	120043	Direct
2007-04-19	Common Stock	S	200	$62.51	Disposed	119843	Direct
2007-04-19	Common Stock	S	200	$62.44	Disposed	119643	Direct
2007-04-19	Common Stock	S	200	$62.43	Disposed	119443	Direct
2007-04-19	Common Stock	S	300	$62.42	Disposed	119143	Direct
2007-04-19	Common Stock	S	200	$62.41	Disposed	118943	Direct
2007-04-19	Common Stock	S	200	$62.40	Disposed	118743	Direct
2007-04-19	Common Stock	S	200	$62.39	Disposed	118543	Direct
2007-04-19	Common Stock	S	200	$62.38	Disposed	118343	Direct
2007-04-19	Common Stock	S	200	$62.37	Disposed	118143	Direct
2007-04-19	Common Stock	S	100	$62.31	Disposed	118043	Direct
2007-04-19	Common Stock	S	800	$62.30	Disposed	117243	Direct
2007-04-19	Common Stock	S	200	$62.27	Disposed	117043	Direct
2007-04-19	Common Stock	S	900	$62.25	Disposed	116143	Direct
2007-04-19	Common Stock	S	400	$62.20	Disposed	115743	Direct
2007-04-19	Common Stock	S	800	$62.19	Disposed	114943	Direct
2007-04-19	Common Stock	S	300	$62.17	Disposed	114643	Direct
2007-04-19	Common Stock	S	400	$62.16	Disposed	114243	Direct
2007-04-19	Common Stock	S	500	$62.15	Disposed	113743	Direct
2007-04-19	Common Stock	S	1500	$62.14	Disposed	112243	Direct
2007-04-19	Common Stock	S	1300	$62.13	Disposed	110943	Direct
2007-04-19	Common Stock	S	1100	$62.12	Disposed	109843	Direct
2007-04-19	Common Stock	S	200	$62.11	Disposed	109643	Direct
2007-04-19	Common Stock	S	200	$62.08	Disposed	109443	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 19, 2007.

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