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                           May 25, 2021

       Safra Catz
       Chief Executive Officer
       Oracle Corp
       2300 Oracle Way
       Austin, TX 78741

                                                        Re: Oracle Corp
                                                            Form 10-K for the
Year Ended May 31, 2020
                                                            Form 10-Q for the
Period Ended February 28, 2021
                                                            File No. 001-35992

       Dear Ms. Catz:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Year Ended May 31, 2020

       Audited Consolidated Financial Statements
       Note 1. Organization and Significant Accounting Policies, page 74

   1.                                                   You disclose on page 78
that your remaining performance obligations were $37 billion as
                                                        of May 31, 2020 and 62%
of that amount is expected to be recognized as revenue over the
                                                        next 12 months. We also
note similar disclosure on page 9 of your Form 10-Q for the
                                                        period ended February
28, 2021. Please revise to disclose (either quantitatively using
                                                        relevant time bands or
qualitatively) when the remaining portion will be recognized.
                                                        Please refer to ASC
606-10-50-13.
 Safra Catz
FirstName
Oracle CorpLastNameSafra Catz
Comapany
May        NameOracle Corp
     25, 2021
May 25,
Page 2 2021 Page 2
FirstName LastName
Form 10-Q for the Period Ended February 28, 2021

Management's Discussion and Analysis
Liquidity and Capital Resources, page 40

2.       In your earnings conference call on March 10, 2021, management
mentioned that the
         Company planned to invest "aggressively" during the fourth quarter of
fiscal 2021 in both
         operating expenses and capital expenditures to address capacity
constraints and prepare
         for an anticipated increase in cloud consumption. Management also
indicated on the call
         that capital expenditures were expected to be $1 billion during the
fourth quarter of 2021,
         which is a material increase compared to the $1.3 billion in capital
expenditures incurred
         during the first nine months of fiscal 2021. There did not appear to
be any mention of
         capacity constraints or planned additional expenditures in your MD&A
for the period
         ended February 28, 2021. Please revise future filings to address the
capacity issues
         encountered, address how these additional investments impacted your
operating
         performance and cash flows for both the fourth quarter 2021 and fiscal
year 2021. Please
         describe the extent to which you anticipate these trends will continue
in future periods.
         Please refer to Item 303 of Regulation S-K.

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

        You may contact Lisa Etheredge, Senior Staff Accountant, at (202)
551-3424 or Robert
S. Littlepage, Accounting Branch Chief, at (202) 551-3361 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology