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: BABB RALPH W JR (Director, Chairman, President & CEO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-19	Common Stock	M	75000	$41.50	Acquired	265444	Direct
2007-04-19	Common Stock	M	50000	$40.32	Acquired	315444	Direct
2007-04-19	Common Stock	S	100	$62.45	Disposed	315344	Direct
2007-04-19	Common Stock	S	1160	$62.41	Disposed	314184	Direct
2007-04-19	Common Stock	S	3040	$62.40	Disposed	311144	Direct
2007-04-19	Common Stock	S	1200	$62.39	Disposed	309944	Direct
2007-04-19	Common Stock	S	25000	$62.355	Disposed	284944	Direct
2007-04-19	Common Stock	S	800	$62.31	Disposed	284144	Direct
2007-04-19	Common Stock	S	25100	$62.30	Disposed	259044	Direct
2007-04-19	Common Stock	S	500	$62.29	Disposed	258544	Direct
2007-04-19	Common Stock	S	700	$62.38	Disposed	257844	Direct
2007-04-19	Common Stock	S	25000	$62.255	Disposed	232844	Direct
2007-04-19	Common Stock	S	300	$62.19	Disposed	232544	Direct
2007-04-19	Common Stock	S	200	$62.18	Disposed	232344	Direct
2007-04-19	Common Stock	S	500	$62.17	Disposed	231844	Direct
2007-04-19	Common Stock	S	26500	$62.16	Disposed	205344	Direct
2007-04-19	Common Stock	S	2000	$62.15	Disposed	203344	Direct
2007-04-19	Common Stock	S	1400	$62.14	Disposed	201944	Direct
2007-04-19	Common Stock	S	4400	$62.13	Disposed	197544	Direct
2007-04-19	Common Stock	S	1400	$62.12	Disposed	196144	Direct
2007-04-19	Common Stock	S	200	$62.11	Disposed	195944	Direct
2007-04-19	Common Stock	S	2100	$62.10	Disposed	193844	Direct
2007-04-19	Common Stock	S	3000	$62.08	Disposed	190844	Direct
2007-04-19	Common Stock	S	100	$62.06	Disposed	190744	Direct
2007-04-19	Common Stock	S	300	$62.04	Disposed	190444	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2007-04-19	Employee Stock Option (right to buy)	$41.50	M	75000	Disposed	2010-03-17	Common Stock (75000)	Direct
2007-04-19	Employee Stock Option (right to buy)	$40.32	M	50000	Disposed	2013-04-17	Common Stock (120000)	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)	$51.43	2011-05-02	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$54.95	2011-09-30	Common Stock (50000)	50000	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (125000)	125000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (150000)	150000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (175000)	175000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (100000)	100000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (100000)	100000	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.