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Exhibit 8.2
FORM OF DORSEY & WHITNEY LLP OPINION
_____________, 2000
Integ Incorporated
2800 Patton Road
St. Paul, Minnesota 55113
Dear Ladies and Gentlemen:
We have acted as your counsel in connection with the
Registration Statement on Form S-4 filed on ________, 2000 (the "Registration
Statement") with the Securities and Exchange Commission under the Securities Act
of 1933, as amended (then "Securities Act"). The Registration Statement relates
to the proposed merger of Integ Incorporated with and into Terrier Acquisition
Corp., a wholly owned subsidiary of Inverness Medical Technology, Inc. This
opinion is delivered in accordance with the requirements of Item 601(b)(8) of
the Regulation S-K under the Securities Act.
In connection with this opinion, we have examined and are
familiar with originals or copies, certified or otherwise identified to our
satisfaction, of the Registration Statement, the Joint Proxy
Statement/Prospectus included therein (the "Joint Proxy Statement/Prospectus")
and such other documents as we have deemed necessary or appropriate.
We hereby confirm that the discussions in the Joint Proxy
Statement/Prospectus under the caption "MATERIAL UNITED STATES FEDERAL INCOME
TAX CONSEQUENCES" are a fair and accurate summary of the matters addressed
therein, based upon current law and the facts and assumptions stated or referred
to therein. There can be no assurance that contrary positions may not be taken
by the Internal Revenue Service.
We hereby consent to the filing of this opinion as Exhibit
8.2 to the Registration Statement and to the use of our name under the
caption "MATERIAL UNITED STATES FEDERAL INCOME TAX CONSEQUENCES" in the Joint
Proxy Statement/Prospectus. In giving such consent, we do not thereby admit
that we are in the category of persons whose consent is required under
Section 7 of the Securities Act.
Very truly yours,
Dorsey & Whitney LLP
