Ownership Submission
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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(Print or Type Responses)
1. Name and Address of Reporting Person *
LAKE JAMES E
   2. Issuer Name and Ticker or Trading Symbol
COMERICA INC /NEW/ [CMA] 		5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
SVP/Dir. of Human Resources
(Last)
(First)
(Middle)
COMERICA BANK, 411W. LAFAYETTE		 3. Date of Earliest Transaction (Month/Day/Year)
10/21/2004
(Street)

DETROIT, MI 48226-3121		 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 10/21/2004   M   3,775 A $ 41.5 14,125 (1) D  
Common Stock 10/21/2004   M   2,512 A $ 51.43 16,637 (1) D  
Common Stock 10/21/2004   M   1,125 A $ 40.32 17,762 (1) D  
Common Stock 10/21/2004   S   7,412 D $ 59.5 10,350 (1) D  
Common Stock               3,513 (2) I by 401k
Common Stock               19 (2) I as UGMA custodian for son
Common Stock               13 (2) I as UGMA custodian for son
Common Stock               17 (2) I as UGMA custodian for daughter

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
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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
Employee Stock Option (right to buy) $ 71.58             01/15/1999(3) 03/20/2008 Common Stock 3,325   3,325 D  
Employee Stock Option (right to buy) $ 66.81             01/14/2000(3) 03/19/2009 Common Stock 3,650   3,650 D  
Employee Stock Option (right to buy) $ 41.5 10/21/2004   M     3,775 01/19/2001(3) 03/17/2010 Common Stock 3,775 $ 0 0 D  
Employee Stock Option (right to buy) $ 51.43 10/21/2004   M     2,512 01/22/2002(3) 05/02/2011 Common Stock 3,350 $ 0 838 D  
Employee Stock Option (right to buy) $ 63.2             01/21/2003(3) 04/17/2012 Common Stock 4,600   4,600 D  
Employee Stock Option (right to buy) $ 40.32 10/21/2004   M     1,125 01/27/2004(3) 04/17/2013 Common Stock 4,500 $ 0 3,375 D  
Employee Stock Option (right to buy) $ 52.5             01/26/2005(3) 04/16/2014 Common Stock 5,000   5,000 D  

Reporting Owners

Reporting Owner Name / Address Relationships
 Director  10% Owner  Officer  Other
LAKE JAMES E
COMERICA BANK
411W. LAFAYETTE
DETROIT, MI 48226-3121		       SVP/Dir. of Human Resources  

Signatures

 /s/ Nicole V. Gersch, on behalf of James E. Lake   10/22/2004
**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) This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of October 1, 2004.
(2) As of October 1, 2004.
(3) The options vest in four equal annual installments beginning on the date indicated in this column.

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