SEC Comment Letter for ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Feb 5, 2013

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: Feb. 5, 2013 · CIK: 0001341439 · Accession: 0000000000-13-006776

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Confidence

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Reasoning

Referenced dates: November 20, 2012

Date

February 5, 2013

Author

/s/ Cecilia Blye

Form

UPLOAD

Company

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE February 5, 2013 Via E -mail 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, 2012 Filed June 26, 2012 File No. 0 -51788

Dear Mr. Ellison:

We refer you to our comment letter dated November 20, 2012, regarding business contacts with Iran, Sudan, and Syria. We have completed our review of this subject matter. 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 defens e in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing inclu des the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE
 February 5, 2013

Via E -mail
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, 2012
  Filed June 26, 2012
  File No. 0 -51788

Dear Mr. Ellison:

We refer you to our comment letter dated November 20, 2012, regarding business
contacts with Iran, Sudan, and Syria.  We have completed our review of this subject matter.  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 defens e in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.  We urge all
persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be
certain that the filing inclu des the information the Securities Exchange Act of 1934 and all
applicable rules require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Barbara Jacobs
  Assistant Director
 Division of Corporati on Finance

SecProbe.io