COMERICA INC — Director's Dealing 2008

Jan 25, 2008

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2008-01-22

Reporting Person: ACTON ELIZABETH S (Exec. V. Pres. and CFO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2008-01-22	Common Stock	A	18445	—	Acquired	63651	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2008-01-22	Employee Stock Option (Right to Buy)	$37.45	A	32000	Acquired	2018-01-22	Common Stock (32000)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (Right to Buy)	$62.02	2012-04-13	Common Stock (30000)	30000	Direct
Employee Stock Option (Right to Buy)	$52.50	2014-04-16	Common Stock (45000)	45000	Direct
Employee Stock Option (Right to Buy)	$54.99	2015-04-21	Common Stock (45000)	45000	Direct
Employee Stock Option (Right to Buy)	$56.47	2016-02-15	Common Stock (32000)	32000	Direct
Employee Stock Option (Right to Buy)	$58.98	2017-01-23	Common Stock (32000)	32000	Direct

Footnotes

F1: Shares of restricted stock awarded under Issuer's Long-Term Incentive Plan.

F2: Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and stock units held pursuant to a deferred compensation plan as of January 22, 2008.

F3: The options vest in four equal annual installments beginning on the date indicated in this column.