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Correspondence

Oracle Corporation

        500 Oracle Parkway

        phone

650.506.7000

        Redwood Shores

        fax

650.506.7200

        California 94065

 January 23, 2013

 VIA EDGAR

 Ms. Cecilia D. Blye, Chief

Office of Global Security Risk

 Division of
Corporation Finance

 United States Securities and Exchange Commission (the “SEC”)

100 F Street, N.E.

 Washington, D.C. 20549-5546

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:

 This will respond to the comments and request for information set forth in your letter to Lawrence J. Ellison, Chief
Executive Officer of Oracle Corporation (“Oracle” or the “Company”), dated November 20, 2012 (the “November 20 Letter”), regarding Oracle’s Form 10-K for the fiscal year ended May 31, 2012. Oracle is
responding to each inquiry with information from May 1, 2010, which is the date up to which we provided similar information in our last response letter to the staff of the SEC (the “Staff”) dated June 4, 2010 (the “Prior
Response Letter”), through November 30, 2012 (the “Relevant Period”). We note that we have previously requested additional time to respond to your comments and request for information.

DESCRIPTION OF CONTACTS OR OPERATIONS WITH IRAN, SYRIA AND SUDAN

 You have asked Oracle to describe the nature and extent of our past, current and anticipated contacts with Iran, Syria and Sudan and their materiality to Oracle. You have also asked us specifically about
our relationships with ZTE Corporation (“ZTE”) and Huawei Technologies Company (“Huawei”) and about any communications we have received from the U.S. Department of Commerce regarding Iran, ZTE and Beijing 8-Star International
Company (“Beijing 8-Star”).

 Ms. Cecilia D. Blye

 Chief, Office of Global Security Risk

 Division of Corporation Finance

United States Securities and Exchange Commission

page 2

 Executive Summary

 In brief, Oracle does not have any business
operations in Iran, Syria or Sudan. In the Relevant Period, the Company is not aware of any new software license transactions in Sudan. The Company is aware of one (1) software license transaction involving a prospective private sector
end-user in Iran conducted by an independent European entity that provided its foreign-produced products commingled with a very small percentage (“De Minimis”), namely 0.33%, of Oracle product for temporary demonstration purposes only.
This transaction was conducted in accordance with U.S. export and sanctions laws and regulations as well as Oracle’s own Global Trade Compliance program. With respect to this one De Minimis export transaction, there was no direct or indirect
financial transaction with the entity in Iran, nor was there any direct or indirect provision of support to the entity in Iran, and Oracle received an insignificant amount of software license revenue from the independent European entity. With
respect to three (3) transactions with two (2) entities from Syria which were approved under export license authorization from the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”), Oracle received an
immaterial amount of revenue during the Relevant Period. Finally, Oracle also received an immaterial amount of software license updates and product support revenue during the Relevant Period associated with the aforementioned new software license
transactions and the transactions previously disclosed in the Prior Response Letter. For all of these transactions, Oracle either obtained all necessary approvals from BIS and/or the U.S. Department of the Treasury’s Office of Foreign
Assets Control (“OFAC”) or no such approvals were required. We believe the amounts for all such transactions, which totaled approximately $3.8 million (0.004% of Oracle’s total revenue) during the Relevant Period, are immaterial to
Oracle and its stockholders.

 In March 2012, Oracle received a subpoena from the U.S. Department of Commerce
regarding the suspected sale or diversion of Oracle’s products by ZTE and/or Beijing 8-Star to an end user in Iran (the “ZTE Subpoena”). On November 29, 2012, the U.S. Department of Commerce Office of Export Enforcement sent
Oracle a letter informing us that it had determined there was no evidence that Oracle was aware of ZTE’s suspected activities and that it had closed its file on this case with respect to Oracle with the issuance of the letter.

During the Relevant Period, Huawei and ZTE were members of Oracle’s alliance partner program with specific rights to resell Oracle
products and services to end users pursuant to the terms and policies relating to such resale transactions that, in particular, required compliance with Oracle’s export restrictions. As discussed below, we do not know of any Oracle products or
services that were resold or diverted to any end users in Iran, Syria or Sudan during the Relevant Period by either Huawei or ZTE.

 Ms. Cecilia D. Blye

 Chief, Office of Global Security Risk

 Division of Corporation Finance

United States Securities and Exchange Commission

page 3

 Details of Oracle’s Limited Contacts with Iran, Syria and Sudan

 Huawei and
ZTE

 The November 20 Letter mentions that there is publicly available information to the effect that Oracle’s Sun
Microsystems servers had been acquired by MTN Irancell, possibly through Huawei. Oracle takes very seriously any allegations regarding sales of Oracle products or services to end users in countries designated as state sponsors of terrorism that were
not in compliance with U.S. and other applicable export laws, regulations and restrictions, and Oracle investigates these allegations thoroughly. Based on the results of our investigation, we are not aware of any sales of Sun servers
to or orders for Sun servers by MTN Irancell (or any other entity in Iran, Sudan, or Syria) directly or indirectly through any authorized distributor or reseller, including Huawei, during the Relevant Period, nor has Oracle received any requests to
provide direct or indirect support of any Sun servers to MTN Irancell.

 The November 20 Letter also requests information
regarding the ZTE Subpoena. As noted in the executive summary above, Oracle received a subpoena in March 2012 from the U.S. Department of Commerce regarding allegations that Oracle’s products had been sold by ZTE and/or Beijing 8-Star to an
Iranian end user. On November 29, 2012, Oracle received a letter from the Office of Export Enforcement (“OEE”) of BIS of the U.S. Department of Commerce stating that OEE appreciated Oracle’s response and cooperation with their
investigation, that OEE had determined that there was no evidence that Oracle was aware of ZTE’s suspected activities and that OEE had closed this case.

 As noted in the executive summary above, the primary relationships between Oracle and Huawei and between Oracle and ZTE during the Relevant Period were that of supplier-distributor under the Oracle
PartnerNetwork program. Huawei and ZTE were also customers of Oracle. As customers, both companies acquired Oracle software program licenses, products and services for their own, internal business purposes. At this time, Huawei and ZTE continue to
be customers of Oracle, and Huawei continues to be a distributor of Oracle’s products under the Oracle PartnerNetwork. Since July 2012, Oracle has permitted ZTE to resell Oracle products and services on a limited and case-by-case basis, after
Oracle has confirmed the identity of the end user and imposed specific compliance requirements. Renewal of ZTE’s formal Oracle PartnerNetwork agreement will be dependent on ZTE’s ability to demonstrate compliance with those
requirements and the implementation of additional controls and processes to ensure compliance with all terms of the agreement, including compliance with export control laws. Oracle has also requested and received confirmation from Huawei of its
compliance with applicable export laws and regulations in connection with its use and distribution of Oracle’s

 Ms. Cecilia D. Blye

 Chief, Office of Global Security Risk

 Division of Corporation Finance

United States Securities and Exchange Commission

page 4

products and services. We are not aware of any Oracle products and services that were resold or diverted to any end users in Iran, Sudan or Syria during the Relevant Period by either Huawei or
ZTE.

 Iran, Syria and Sudan Generally

 Oracle (including its subsidiaries) does not maintain any offices, employees, agents or affiliates in Iran, Syria or Sudan, and no such operations are anticipated. Oracle does not have any authorized
resellers or distributors based in Iran, Syria or Sudan, or any resellers or distributors authorized to resell or distribute Oracle products into any of those countries, and none are anticipated. Oracle has authorized distributors and resellers, as
well as customers, based in other countries around the world who may themselves conduct business operations in Iran, Syria and Sudan. However, the terms of our Oracle PartnerNetwork Agreements and Distribution Agreements governing reseller and
distributor relationships, and our License and Services Agreements for end users, provide clear notice that the export control laws of the United States apply to the Oracle software programs licensed and distributed and require compliance with such
laws.

 From time to time during the Relevant Period, Oracle may have received sales inquiries regarding its software products
or related services from or for end users in Iran, Syria or Sudan. To the extent such inquiries were received by our various Oracle offices, Oracle policy requires that they be directed to Oracle’s Office of Global Trade Compliance to ensure
that they were handled in compliance with all applicable export laws and regulations. In addition to such standard compliance controls, Oracle’s Office of Global Trade Compliance has implemented Oracle Global Trade Management (GTM), an
automation platform that enables Oracle to achieve best practices in global trade compliance, including but not limited to, transactional compliance screening against restricted parties, embargoed and high-risk countries, and red-flag compliance
criteria. GTM flags and prevents execution of any potential transactions that may be contrary to U.S. or other applicable export laws and regulations and supports the conduct of export compliance due diligence with respect to such potential
transactions in an effort to ensure compliance with all applicable export laws and regulations and Oracle’s export compliance policies.

 Oracle did not have any direct contact with or provide any products or services directly to end users in Iran during the Relevant Period. Oracle did receive notice during the Relevant Period from an
independent European entity of one (1) re-export of foreign-produced product that commingled a single Oracle software program constituting, based on this independent European entity’s calculations, 0.33 percent (0.33%) of the independent
European entity’s foreign-produced product (a “De Minimis re-export” at 10% or less) to one (1) stated private sector recipient in Iran for temporary demonstration

 Ms. Cecilia D. Blye

 Chief, Office of Global Security Risk

 Division of Corporation Finance

United States Securities and Exchange Commission

page 5

 purposes, as permitted under applicable De Minimis or other U.S. export license exemptions available under the U.S. Export Administration Regulations (“EAR”) administered by BIS and the Iranian
Transactions Regulations (now titled the Iranian Transactions and Sanctions Regulations) (31 C.F.R. – Part 560) administered by OFAC. The software license contract amount paid by the independent European entity associated with this one De
Minimis temporary demonstration for the one stated end user in Iran was $519, and the associated first year support contract amount paid by the same European entity was $99 (even though neither such European entity nor Oracle provided support to
such stated recipient in Iran with respect to the temporary demo), for a total of $618. The information regarding this one De Minimis exception was made available to Oracle from the independent European entity, and Oracle did not facilitate the
transaction in any way. Oracle did not engage in any direct or indirect financial transactions with the entity in Iran nor was any support provided directly or indirectly by Oracle to the entity in Iran.

Oracle was directly involved in three (3) new software license and related software support transactions with two (2) private
sector end users in Syria during the Relevant Period. All three transactions were made pursuant to the laws administered and export licenses granted by the BIS. The contract amounts received by Oracle in connection with these three new transactions
during the Relevant Period totaled $2,366,031 for the new software licenses and $520,474 for the related software support contracts, for a total of $2,886,505. Oracle does not know or have reason to know of any De Minimis re-exports during the
Relevant Period to either Syria or Sudan.

 During the Relevant Period, in addition to the three software license and related
software support transactions with the two end users in Syria referenced above, Oracle had limited contacts directly with certain other end users in Syria and with one end user in Sudan. All of these end users were referenced in Oracle’s Prior
Response Letter. As was disclosed in the Prior Response Letter, the sales to these other end users in Syria and Sudan were conducted largely by resellers or distributors of Oracle’s products or were made by independent foreign entities
involving their products commingled with a De Minimis amount of Oracle products. With respect to the end user in Sudan, certain non-U.S. Oracle subsidiaries during the Relevant Period provided some assistance, as permitted by U.S. law, but no
support services were provided to this end user by any Oracle entities in the U.S., and Oracle did not receive any payments directly from this end user. We have concluded that our contacts during the Relevant Period with these other end users
in Syria and Sudan were conducted in accordance with U.S. export regulations and U.S. sanctions, and either necessary approvals from BIS and OFAC were obtained or no such approvals were required. The amounts of the software support contracts during
the Relevant Period associated with all transactions from end users in Syria and Sudan referenced in our Prior Response Letter totaled $954,323.

 Ms. Cecilia D. Blye

 Chief, Office of Global Security Risk

 Division of Corporation Finance

United States Securities and Exchange Commission

page 6

Oracle does not anticipate conducting business with or for end users in Iran or Sudan but cannot anticipate or control De Minimis
re-export transactions by independent foreign entities. If Oracle were to learn of proposed export, re-export or use of Oracle products or services in these countries, our Office of Global Trade Compliance would process such cases in accordance with
U.S. and applicable foreign and multilateral export compliance laws and regulations. The Company anticipates a low volume of software license and related software support transactions with or for entities in Syria, in compliance with applicable U.S.
export and sanctions laws and regulations.

 MATERIALITY

 You have asked Oracle to assess the materiality of any contacts with entities in Iran, Syria and Sudan and whether those contacts constitute a material investment risk for Oracle’s security holders.

 The Company believes that a reasonable investor would be unlikely to consider Oracle to be doing business in Iran or Syria
based on a limited number of transactions pursuant to valid U.S. export licenses approved by the U.S. Government or based on the limited re-export of Oracle software products initiated by ind