SecProbe.io

March 25, 2011
 Via E-mail

Mr. Lawrence J. Ellison Chief Executive Officer and Director Oracle Corporation 500 Oracle Parkway Redwood City, CA 94065
Re: Oracle Corporation
 Form 10-K for the Fiscal Year ended May 31, 2010
Filed July 1, 2010 File No. 000-51788

Dear Mr. Ellison:
 We have reviewed your letter dated Febr uary 17, 2011 in connection with the above-
referenced filing and have the following comments.   In some of our comments, we may ask you
to provide us with information so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have addi tional comments.  Unless otherwise noted, where
prior comments are referred to they refer to our letter dated February 3, 2011.
          Form 10-K for the Fiscal Year ended May 31, 2010

Consolidated Financial Statements
 Consolidated Statements of Operations, page 88

1. We note your response to prior comment 5.  Pl ease provide us with your quantitative
analysis of the allocation of such costs to the respective cost of sales for the periods
presented and describe how you considered the significance of these costs relative the
respective revenue streams and the costs of sales line items currently presented on your
Statements of Operations.  In addition, tell  us how you considered the guidance of ASC
985-20-45-1 and SAB Topic 11.B.

 Lawrence J. Ellison Oracle Corporation March 25, 2011 Page 2
 2. As a related matter, please explain to us w hy you do not present cost of sales related to
new software licenses.  We note that in your November 23, 2005 response to comment 81
you indicated that if the amortization of developed technology amounts becomes
significant, you will present the cost of licenses, including the amortization of developed
technology, separately in future filings.  In your response, quantify the components of the
direct costs of new software licenses revenue s for the periods presen ted and describe how
you considered the significance of these cost s relative to the new licenses revenues.
Please refer to Item 5- 03.2 of Regulation S-X.
 Notes to Consolidated Financial Statements

 Note 1. Organization and Si gnificant Accounting Policies

 Revenue Recognition, page 91

 3. In your response to prior comment 7 you indica te that Premier Support is available for
the first five years from the general availability date of all product releases.  Please explain what you mean by the general availabi lity date for a product and how this is
factored into a support contra ct term period.  Clarify whet her Premier Support is a five-
year support contract sold in connection with  a software license or whether customers
simply have the option of renewing an annual contract during this five-year period.  In
this regard, we note in your response your reference to first year support sold in
connection with a software license although in  your description of Premier Support on
your website, it appears to be a standard five-year support period.
 You may contact Joyce Sweeney, Staff Accountant at (202) 551-3449 if you have
questions regarding comments on th e financial statements and related matters.  If you have any
other questions, please contact Philip Rothenberg , Staff Attorney, at (202) 551-3466 or Barbara
C. Jacobs, Assistant Director, at (202) 551- 3730.  If you require furt her assistance, do not
hesitate to contact me at (202) 551-3406.
Sincerely,
   /s/ Patrick Gilmore
Patrick Gilmore Accounting Branch Chief