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SEC Company Response from ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439) (ORCL) — Jan 29, 2016

ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)
Date: Jan. 29, 2016 · CIK: 0001341439 · Accession: 0001193125-16-443241

Regulatory Compliance Financial Reporting Internal Controls

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Confidence
SEC Posture
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Summary

Reasoning

Date
January 29, 2016
Author
/s/ Kimberly Woolley
Form
CORRESP
Company
ORACLE CORP (ORCL, ORCL-PD) (CIK 0001341439)

Letter

VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission Oracle Corporation Form 10-K for the Fiscal Year Ended May 31, 2015 Filed June 25, 2015 File No. 1-35992

Dear Ms. Blye:

This will acknowledge receipt of your request for information set forth in your letter to Mark V. Hurd, Chief Executive Officer of Oracle Corporation, dated January 20, 2016, regarding Oracle’s Form 10-K for the fiscal year ended May 31, 2015. We understand that this is a standard inquiry being made of many public companies by the SEC’s Office of Global Security Risk, created to assist in the fight against global terrorism.

We would like to request additional time to respond to your comments and complete our due diligence so that we can respond as thoroughly and completely as possible. We expect to be able to provide our response during the week of March 28, 2016. If you have any further questions, please contact me at (650) 506-7000.

Very truly yours,
/s/ Kimberly Woolley

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Letter to the SEC

500 Oracle Parkway

phone

+16505067000

Redwood Shores

oracle.com

California 94065

 January 29, 2016

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, 2015

Filed June 25, 2015

File No. 1-35992

 Dear Ms. Blye:

This will acknowledge receipt of your request for information set forth in your letter to Mark V. Hurd, Chief Executive Officer of Oracle
Corporation, dated January 20, 2016, regarding Oracle’s Form 10-K for the fiscal year ended May 31, 2015. We understand that this is a standard inquiry being made of many public companies by the SEC’s Office of Global Security
Risk, created to assist in the fight against global terrorism.

 We would like to request additional time to respond to your comments and
complete our due diligence so that we can respond as thoroughly and completely as possible. We expect to be able to provide our response during the week of March 28, 2016. If you have any further questions, please contact me at
(650) 506-7000.

 Very truly yours,

 /s/ Kimberly Woolley

 Kimberly Woolley

 Assistant General Counsel and Assistant Secretary

 cc:

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

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

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

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