SEC Company Response from ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Oct 24, 2011
ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: Oct. 24, 2011 · CIK: 0001341439 · Accession: 0001193125-11-278885
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-176405
Letter
United States Securities and Exchange Commission Division of Corporate Finance Oracle Corporation Re: Registration Statement on Form S-4 filed August 19, 2011 File No. 333-176405 Request for Acceleration of Effectiveness
Dear Mr. Crispino:
In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Oracle Corporation (the “Company”) hereby requests that the effectiveness of the above referenced Registration Statement on Form S-4 (the “Registration Statement”) be accelerated to 4:00 p.m., Eastern Time, on October 26, 2011, or as soon thereafter as practicable.
The Company acknowledges that the disclosure in the Registration Statement is the responsibility of the Company. The Company hereby represents to the United States Securities and Exchange Commission (the “Commission”) that:
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should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
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the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
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the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact Sarah K. Solum (650-752-2011) at Davis Polk & Wardwell LLP with any questions you may have concerning this request.
Very truly yours,
Oracle Corporation
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CORRESP 1 filename1.htm Correspondence [ORACLE CORPORATION LETTERHEAD] October 24, 2011 Mr. Matthew Crispino United States Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 Oracle Corporation Re: Registration Statement on Form S-4 filed August 19, 2011 File No. 333-176405 Request for Acceleration of Effectiveness Dear Mr. Crispino: In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Oracle Corporation (the “Company”) hereby requests that the effectiveness of the above referenced Registration Statement on Form S-4 (the “Registration Statement”) be accelerated to 4:00 p.m., Eastern Time, on October 26, 2011, or as soon thereafter as practicable. The Company acknowledges that the disclosure in the Registration Statement is the responsibility of the Company. The Company hereby represents to the United States Securities and Exchange Commission (the “Commission”) that: • should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact Sarah K. Solum (650-752-2011) at Davis Polk & Wardwell LLP with any questions you may have concerning this request. Very truly yours, Oracle Corporation By: /s/ Christopher Ing Name: Christopher Ing Title: Assistant General Counsel and Assistant Secretary 2