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SEC Company Response from ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Jan 4, 2013

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: Jan. 4, 2013 · CIK: 0001341439 · Accession: 0001193125-13-003707

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File numbers found in text: 000-51788

Date
January 4, 2013
Author
/s/ Christopher Ing
Form
CORRESP
Company
ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)

Letter

VIA EDGAR Office of Global Security Risk Division of Corporation Finance United States Securities and Exchange Commission Re: Oracle Corporation Form 10-K for the Fiscal Year Ended May 31, 2012 Filed June 26, 2012 File No. 000-51788

Dear Ms. Blye:

We are writing with regards to your request for information set forth in your letter to Lawrence J. Ellison, Chief Executive Officer of Oracle Corporation (“Oracle”), dated November 20, 2012, regarding Oracle’s Form 10-K for the fiscal year ended May 31, 2012. We are writing to request additional time to respond.

While we initially expected to provide our response during the week of December 31, 2012, we now seek additional time to complete our due diligence and to provide a comprehensive response consistent with Oracle’s previous communications on these matters. We now expect to respond by January 23, 2013. If you have any further questions, please contact me at (650) 506-7000.

Very truly yours,
/s/ Christopher Ing

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CORRESP
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Correspondence

500 Oracle Parkway

phone

+16505067000

Redwood Shores

oracle.com

California 94065

 January 4, 2013

 VIA EDGAR

 Ms. Cecilia D. Blye, Chief

Office of Global Security Risk

 Division of
Corporation Finance

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
Oracle Corporation

Form 10-K for the Fiscal Year Ended May 31, 2012

Filed June 26, 2012

File No. 000-51788

 Dear Ms. Blye:

 We are writing with regards to your request for information set forth in your letter to Lawrence J. Ellison, Chief Executive
Officer of Oracle Corporation (“Oracle”), dated November 20, 2012, regarding Oracle’s Form 10-K for the fiscal year ended May 31, 2012. We are writing to request additional time to respond.

While we initially expected to provide our response during the week of December 31, 2012, we now seek additional time to complete
our due diligence and to provide a comprehensive response consistent with Oracle’s previous communications on these matters. We now expect to respond by January 23, 2013. If you have any further questions, please contact me at
(650) 506-7000.

 Very truly yours,

 /s/ Christopher Ing

 Christopher Ing

 Assistant General Counsel and Assistant Secretary

cc:
Barbara Jacobs, Assistant Director, Division of Corporation Finance, SEC

Pradip Bhaumik, Special Counsel, Office of Global Security Risk, Division of Corporation Finance, SEC

Dorian Daley, Senior Vice President, General Counsel and Secretary, Oracle Corporation

William Corey West, Senior Vice President and Chief Accounting Officer, Oracle Corporation

Brian S. Higgins, Vice President, Associate General Counsel and Assistant Secretary, Oracle Corporation