0001193125-11-278885.txt : 20120103 0001193125-11-278885.hdr.sgml : 20120102 20111024182606 ACCESSION NUMBER: 0001193125-11-278885 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20111024 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ORACLE CORP CENTRAL INDEX KEY: 0001341439 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 542185193 FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 500 ORACLE PARKWAY STREET 2: MAIL STOP 5 OP 7 CITY: REDWOOD CITY STATE: CA ZIP: 94065 BUSINESS PHONE: 6505067000 MAIL ADDRESS: STREET 1: 500 ORACLE PARKWAY STREET 2: MAIL STOP 5 OP 7 CITY: REDWOOD CITY STATE: CA ZIP: 94065 FORMER COMPANY: FORMER CONFORMED NAME: Ozark Holding Inc. DATE OF NAME CHANGE: 20051013 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:

 

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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

By:

  

/s/ Christopher Ing

  Name:   Christopher Ing
  Title:   Assistant General Counsel and Assistant Secretary

 

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