FORM 4 Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP OF SECURITIES Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person * FRIDHOLM ROGER   2. Issuer Name and Ticker or Trading Symbol COMERICA INC /NEW/ [CMA] 5. Relationship of Reporting Person(s) to Issuer (Check all applicable) __X__ Director _____ 10% Owner _____ Officer (give title below) _____ Other (specify below) (Last) (First) (Middle) 500 WOODWARD AVE., 31ST FLOOR 3. Date of Earliest Transaction (Month/Day/Year) 04/27/2005 (Street) DETROIT, MI 48226 4. If Amendment, Date Original Filed(Month/Day/Year) 6. Individual or Joint/Group Filing(Check Applicable Line) _X_ Form filed by One Reporting Person ___ Form filed by More than One Reporting Person (City) (State) (Zip) Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned

1.Title of Security (Instr. 3) 2. Transaction Date (Month/Day/Year) 2A. Deemed Execution Date, if any (Month/Day/Year) 3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4) Code V Amount (A) or (D) Price Common Stock 04/27/2005   S   1,500 D $ 57.138 12,315 (1) D (2)   Common Stock               1,000 I by Spouse

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Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)

1. Title of Derivative Security (Instr. 3)

2. Conversion or Exercise Price of Derivative Security

3. Transaction Date (Month/Day/Year)

3A. Deemed Execution Date, if any (Month/Day/Year)

4. Transaction Code (Instr. 8)

5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4, and 5)

6. Date Exercisable and Expiration Date (Month/Day/Year)

7. Title and Amount of Underlying Securities (Instr. 3 and 4)

8. Price of Derivative Security (Instr. 5)

9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)

10. Ownership Form of Derivative Security: Direct (D) or Indirect (I) (Instr. 4)

11. Nature of Indirect Beneficial Ownership (Instr. 4)

Code

V

(A)

(D)

Date Exercisable

Expiration Date

Title

Amount or Number of Shares

Director Stock Option (right to buy)

$ 19.92

04/27/2005

M

1,500

05/19/1996

05/19/2005

Common Stock

1,500

$ 0

0

D

Director Stock Option (right to buy)

$ 29.08

05/17/1997

05/17/2006

Common Stock

1,500

1,500

D

Director Stock Option (right to buy)

$ 40.09

05/16/1998

05/16/2007

Common Stock

1,500

1,500

D

Director Stock Option (right to buy)

$ 65.13

05/15/1999

05/15/2008

Common Stock

1,500

1,500

D

Director Stock Option (right to buy)

$ 62.75

05/21/2000

05/21/2009

Common Stock

1,500

1,500

D

Director Stock Option (right to buy)

$ 44.13

05/19/2001

05/19/2010

Common Stock

2,000

2,000

D

Director Stock Option (right to buy)

$ 57.15

05/22/2002

05/20/2011

Common Stock

2,500

2,500

D

Director Stock Option (right to buy)

$ 64.5

05/21/2003

05/21/2012

Common Stock

2,500

2,500

D

Director Stock Option (right to buy)

$ 43.63

05/20/2004

05/20/2013

Common Stock

2,500

2,500

D

Director Stock Option (right to buy)

$ 53.87

05/18/2005

05/18/2014

Common Stock

2,500

2,500

D

Restricted Stock Units

$ 0 (3)

08/08/1988(4)

08/08/1988(4)

Common Stock

319

319

D

Reporting Owners

Reporting Owner Name / Address	Relationships
	Director	10% Owner	Officer	Other
FRIDHOLM ROGER 500 WOODWARD AVE. 31ST FLOOR DETROIT, MI 48226	X

Signatures

/s/ Nicole V. Gersch, on behalf of Roger Fridholm		04/28/2005
**Signature of Reporting Person		Date

Explanation of Responses:

*	If the form is filed by more than one reporting person, see Instruction 4(b)(v).
**	Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1)	Includes 200 shares held in an IRA.
(2)	Includes stock units held pursuant to deferred director plans and shares purchased with reinvested dividends as of April 1, 2005.
(3)	Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.
(4)	The restricted stock units vest one year after the date of grant. Vested shares are settled one year after the insider's date of retirement.

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