September 11, 2000

Mr. W. Stephen Smith
Morrison and Foerster LLP
Counsel for Oracle Corporation
2000 Pennsylvania Avenue, N.W.
Washington, D.C. 20006-1888

Re: Covisint, File No. 001 0127

Dear Mr. Smith:

The Commission has conducted an investigation to determine whether the formation of Covisint violates Section 7 of the Clayton Act. Upon further review of this matter, it now appears that no further action is warranted by the Commission at this time. Accordingly, the investigation has been closed.

This action is not to be construed as a determination that a violation may not have occurred, just as the pendency of an investigation should not be construed as a determination that a violation has occurred. Because Covisint is in the early stages of its development and has not yet adopted bylaws, operating rules, or terms for participant access, because it is not yet operational, and in particular because it represents such a large share of the automobile market, we cannot say that implementation of the Covisint venture will not cause competitive concerns.

In view of the undeveloped status of Covisint, the Commission reserves the right to take such further action as the public interest may require.

By direction of the Commission, Commissioner Leary recused.

Donald S. Clark