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SEC Comment Letter for ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Feb 16, 2012

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: Feb. 16, 2012 · CIK: 0001341439 · Accession: 0000000000-12-008556

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
May 31, 2011
Author
/s/ Patrick Gilmore
Form
UPLOAD
Company
ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)

Letter

February 16, 201 2 Via E -mail Safra A. Catz President and Chief Financial Officer Oracle Corporation 500 Oracle Parkway Redwood City, CA 94065

Re: Oracle Corporation Form 10 -K for the Fiscal Year Ended May 31, 2011 Filed June 28, 2011 File No. 000 -51788

Dear Ms. Catz:

We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We u rge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Patrick Gilmore

Show Raw Text
February  16, 201 2

Via E -mail
Safra A. Catz
President  and Chief Financial Officer
Oracle Corporation
500 Oracle Parkway
Redwood City, CA 94065

Re: Oracle Corporation
 Form 10 -K for the Fiscal Year Ended May 31, 2011
 Filed June 28, 2011
File No. 000 -51788

Dear  Ms. Catz:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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.  We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Patrick Gilmore

 Patrick Gilmore
Accounting Branch Chief