May 12, 2006
Via EDGAR Transmission and Fax
Daniel F. Duchovny, Esq.
Division of Corporation Finance
U.S. Securities and Exchange Commission
Station Place, 100 F Street
Washington, D.C. 20549-3628
| Re: | Portal Software, Inc. Schedule TO-C filed April 13, 2006 Schedule TO-T filed April 25, 2006, by Potter Acquisition Corp., Oracle Systems Corporation and Oracle Corporation SEC File No. 005-58301 |
As previously requested in your letter dated May 2, 2006, Potter Acquisition Corporation (“Offeror”), Oracle Systems Corporation (“Parent”) and Oracle Corporation (“Oracle”) hereby acknowledge that:
| • | Offeror, Parent and Oracle are responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | Offeror, Parent and Oracle may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
In this letter, the capitalized term “Commission” means U.S. Securities and Exchange Commission and the capitalized term “Staff” means the Commission’s staff.
[Rest of Page Intentionally Left Blank]
Sincerely yours, | ||
POTTER ACQUISITION CORPORATION | ||
| By: | /S/ DANIEL COOPERMAN | |
| Name: | Daniel Cooperman | |
| Title: | President and Chief Executive Officer | |
ORACLE SYSTEMS CORPORATION | ||
| By: | /S/ SAFRA A. CATZ | |
| Name: | Safra A. Catz | |
| Title: | President and Chief Financial Officer | |
ORACLE CORPORATION | ||
| By: | /S/ SAFRA A. CATZ | |
| Name: | Safra A. Catz | |
| Title: | President and Chief Financial Officer | |
