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Mail Stop 4561         February 27, 2008  Lawrence J. Ellison Chief Executive Officer Oracle Corp. 500 Oracle Parkway Redwood Cit y, CA 94065

Re: Oracle Corp.
Form 10-K for Fiscal Ye ar Ended May 31, 2007
 Filed June 29, 2007  File No. 000-51788

Dear Mr. Ellison:

We have reviewed the above referenced filing and have the following comments.
If indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In
some of our comments, we may ask you to provide us with supplemental information so
we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-K for Fiscal Year Ended May 31, 2007

Item 8.  Financial Statements and Supplementary Data

1.  Organization and Significant Accounting Policies

Revenue Recognition, page 71
1. We note that you recognize no more than 90% of the milestone or total contract
amount until project acceptance is obtaine d for fixed-price service arrangements
where you can measure progress towards co mpletion.  Please explain to us the

Lawrence J. Ellison
Oracle Corp.
February 27, 2008 Page 2
nature of the customer acceptance prov isions that are included in these
arrangements and explain your basis for this 90% policy.  Refer to any accounting
guidance as appropriate.
 2.  Acquisitions

 Fiscal 2007 Acquisitions, page 78

2. We note your reference to the valuation that was used to value the intangible
assets and deferred revenue acquired in business combinations.  Please note that
when you refer to an independent valua tion specialist you shou ld disclose the
specialist’s name and, if your annual report is incorporated by reference into a
Securities Act registration statement, incl ude the appropriate consent.  Refer to
Rule 436(b) of Regulation C and f ile the consent, if necessary.
 Item 15.  Exhibits and Financial Statement Schedules

3. You do not appear to have filed as exhi bits to your annual report any contracts
relating to the transactions with relate d persons disclosed in Note 20 to your
financial statements and on page 42 of your proxy statement.  Please tell us why you have not filed any related party agr eements. See Item 601(b)(10)(ii)(A) of
Regulation S-K.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Lawrence J. Ellison
Oracle Corp. February 27, 2008 Page 3
In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Mark Shannon, Sta ff Accountant, at (202) 551-3299 or
Christine Davis, Senior Staff Accountant,  at (202) 551-3408 if you have any questions
regarding comments on the fina ncial statements and relate d matters.  Please address
questions regarding all other comments to Ka therine Wray, Staff Attorney, at (202) 551-
3483 or David Orlic, Special Counsel, at (202)  551-3503.  If you need further assistance,
you may contact me at (202) 551-3451.

      S i n c e r e l y ,
                Mark Kronforst
Accounting Branch Chief