COMERICA INC — Director's Dealing 2008

Jul 9, 2008

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2008-07-08

Reporting Person: BAUDER LILLIAN (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2008-07-08	Common Stock	A	109	$26.29	Acquired	26077	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Director Stock Option (right to buy)	$62.75	2009-05-21	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$64.50	2012-05-21	Common Stock (2500)	2500	Direct
Restricted Stock Units	$0	1988-08-08	Common Stock (319)	319	Direct

Footnotes

F1: The shares were acquired by reporting person in connection with a distribution from one of issuer's director deferral plans.

F2: The shares that were acquired by reporting person in connection with this transaction have been included in Table I of previous filings, and accordingly, this transaction does not vary the amount of securities beneficially owned by reporting person.

F3: Includes stock units held pursuant to deferred director plans, resticted stock units, and shares purchased with reinvested dividends as of July 8, 2008.

F4: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F5: 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.