Exhibit 8.2 [Letterhead of Wilson Sonsini Goodrich & Rosati, Professional Corporation] S-4 OPINION Occam Networks Inc. 77 Robin Hill Road Santa Barbara, California 93117 Re: Agreement and Plan of Merger and Reorganization (the "Agreement") dated as of...Agreement and Plan of Merger and Reorganization • February 11th, 2002 • Accelerated Networks Inc • Computer communications equipment
