SecProbe.io

March 17, 2010

Via U.S. Mail and Facsimile (650-506-7200)
 Lawrence J. Ellison Chief Executive Officer Oracle Corporation 500 Oracle Parkway
Redwood City, California 94065

 Re: Oracle Corporation
Form 10-K for the Fiscal Year Ended May 31, 2009
Filed June 29, 2009
  File No. 0-51788
Dear Mr. Ellison:

We have limited our review of your f ilings to disclosure relating to your
contacts with countries that have been identified as state sponsors of terrorism, and we
have the following comments.  Our review w ith respect to this issue does not preclude
further review by the Assistant Director  group with respect to other issues.   At this
juncture, we are asking you to provide us with supplemental information, so that we
may better understand your disclosure.  Please be as detailed as necessary in your response.  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 filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the tele phone numbers listed at th e end of th is letter.

General

1. You state on page 41-42 and 44-50 that you earned revenues from the Americas
and from the Middle East and Africa,  references generally understood to
encompass Cuba, Iran, Sudan, and Syria.  Further, on your website you provide
contact information pertaining to sales, t echnical support, and education related to
Syria.  In addition, we are aware of a July 2008 news report that Dubai Islamic
Bank, which owns interests in certain Sudanese banks, adopted your software
across all its branches an d networks.  We are also aware of a September 2009
news report that the centr al bank of Syria ordered your software to run its
operations.
As you know, Cuba, Iran, Sudan, and Syria ar e countries that ar e identified by the
State Department  as state sponsors of terrorism, and are subject to U.S. economic
sanctions and export controls.  We not e that your Form 10-K does not include
disclosure regarding contacts with Cuba, Iran, Sudan, and Syria.  Please describe

Lawrence J. Ellison
Oracle Corporation
March 17, 2010 Page 2
to us the nature and extent of your past , current, and antici pated contacts with
Cuba, Iran, Sudan, and Syria, whether through subsidiaries, distributors, resellers,
or other direct or indir ect arrangements, since your response letter to the staff
dated February 20, 2007.  Your resp onse should describe any products,
technology, software, or services that you have provided into Cuba, Iran, Sudan,
and Syria, directly or indirectly, and any agreements, commercial arrangements,
or other contacts you have had with the gove rnments of those countries or entities
controlled by those governments.

2. Please discuss the materiality of any cont acts with Cuba, Iran, Sudan, and Syria,
and whether those contacts constitute a material investment risk for your security holders.  You should address materiality in quantitative term s, including the
approximate dollar amounts of any associat ed revenues, assets, and liabilities for
the last three fiscal years and any subsequent period.  Also, address materiality in terms of qualitative factors that a reasona ble investor would deem important in
making an investment decision, including the potential impact of corporate
activities upon a company’s reputation a nd share value.  As you know, various
state and municipal governments, universi ties, and other inve stors have proposed
or adopted divestment or similar initiatives regarding investment in companies that do business with U.S.-designated state sponsors of terrorism.  Your
materiality analysis should address the pot ential impact of the investor sentiment
evidenced by such actions directed toward companies that have contacts with
Cuba, Iran, Sudan, and Syria.

* * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a re sponse.  Please submit your response letter on EDGAR.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filings include all in formation required under
the Exchange Act of 1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to the company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
 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
filings;
 • staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

Lawrence J. Ellison
Oracle Corporation March 17, 2010 Page 3
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 filings or in response to our comments on your filings.
  Please understand that we may have addi tional comments after we review your
response to our comments.  Pl ease contact Pradip Bhaumik, Special Counsel, at (202)
551-3333 if you have any questions about the comments or our review.  You may also contact me at (202) 551-3470.          S i n c e r e l y ,             C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk   cc:  Barbara Jacobs   Assistant Director  Division of Corporation Finance