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SEC Comment Letter for ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Apr 4, 2016

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: April 4, 2016 · CIK: 0001341439 · Accession: 0000000000-16-070751

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: January 23, 2016

Date
March 23, 2016
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)

Letter

Mailstop 4628 March 23, 2016 Via E -mail Mark V. Hurd 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, 2015 Filed June 25, 2015 File No. 1 -35992

Dear Mr. Hurd:

We refer you to our comment letter dated January 23, 2016, regarding business contacts with 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 defense 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 includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
Mailstop 4628

March 23, 2016
Via E -mail
Mark V. Hurd
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, 2015
Filed June 25, 2015
File No. 1 -35992

Dear Mr. Hurd:

We refer you to our comment letter dated January 23, 2016, regarding business contacts
with 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 defense 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 includes 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 Corporation Finance