July 12, 2024

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, 2024
           File No. 001-35992
Dear Safra Catz:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended May 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Cloud and License Business, page 40

1.     With a view towards enhanced investor understanding, in future filings
please present a
       quantified discussion of customer migrations from software licenses and
the related
       license support to the Oracle Cloud.
Results of Operations, page 44

2.     Please expand your results of operations discussion throughout to
provide a more
       comprehensive and quantified discussion and analysis of the factors that
impacted your
       results during the comparative periods. In circumstances where there are
multiple factors
       that are material to a change, please quantify the incremental impact of
each factor on the
       overall change. For example, quantify how much of the increase in your
cloud and license
       business    total revenues was due to changes in volumes sold, changes
in selling prices,
       changes in product mix, and the net impact of the changes in foreign
currency exchange
       rates. See Item 303(b)(2) of Regulation S-K.
 July 12, 2024
Page 2

       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.

      Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-551-
3361 with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology