SEC Comment Letter 0000000000-24-008676 to ORACLE CORP (ORCL) (CIK 0001341439) (ORCL)
ORACLE CORP (ORCL) (CIK 0001341439)
Date: July 30, 2024 · CIK: 0001341439 · Accession: 0000000000-24-008676
AI Filing Summary & Sentiment
File numbers found in text: 001-35992
Letter
July 30, 2024 Safra Catz Chief Executive Officer Oracle Corp 2300 Oracle Way Austin, TX 78741 Re:Oracle Corp Form 10-K for the Year Ended May 31, 2024 Response dated July 26, 2024 File No. 001-35992 Dear Safra Catz: We have reviewed your July 26, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our July 12, 2024 letter. Form 10-K for the year ended May 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Cloud and License Business, page 40 1.We note your response to prior comment 1. In light of your discussions of cloud services revenues in your quarterly filings, please explain to us why you will not provide a quantified discussion of customer migrations in your forthcoming Form 10-Q. Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551- 3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance
July 30, 2024 Page 2 Office of Technology
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July 30, 2024
Safra Catz
Chief Executive Officer
Oracle Corp
2300 Oracle Way
Austin, TX 78741
Re:Oracle Corp
Form 10-K for the Year Ended May 31, 2024
Response dated July 26, 2024
File No. 001-35992
Dear Safra Catz:
We have reviewed your July 26, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our July 12, 2024 letter.
Form 10-K for the year ended May 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Cloud and License Business, page 40
1.We note your response to prior comment 1. In light of your discussions of cloud services
revenues in your quarterly filings, please explain to us why you will not provide
a quantified discussion of customer migrations in your forthcoming Form 10-Q.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551-
3361 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
July 30, 2024
Page 2
Office of Technology