COMERICA INC — Director's Dealing 2008

Jan 30, 2008

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2008-01-29

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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2008-01-29	Common Stock	S	400	$40.90	Disposed	118608	Direct
2008-01-29	Common Stock	S	800	$40.92	Disposed	117808	Direct
2008-01-29	Common Stock	S	200	$40.93	Disposed	117608	Direct
2008-01-29	Common Stock	S	900	$40.94	Disposed	116708	Direct
2008-01-29	Common Stock	S	200	$40.95	Disposed	116508	Direct
2008-01-29	Common Stock	S	100	$40.96	Disposed	116408	Direct
2008-01-29	Common Stock	S	200	$40.97	Disposed	116208	Direct
2008-01-29	Common Stock	S	600	$40.98	Disposed	115608	Direct
2008-01-29	Common Stock	S	1100	$40.99	Disposed	114508	Direct
2008-01-29	Common Stock	S	300	$41.00	Disposed	114208	Direct
2008-01-29	Common Stock	S	200	$41.01	Disposed	114008	Direct
2008-01-29	Common Stock	S	300	$41.02	Disposed	113708	Direct
2008-01-29	Common Stock	S	200	$41.03	Disposed	113508	Direct
2008-01-29	Common Stock	S	1400	$41.04	Disposed	112108	Direct
2008-01-29	Common Stock	S	100	$41.05	Disposed	112008	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
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (51000)	51000	Direct

Footnotes

F1: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of January 29, 2008.

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