FIRM / AFFILIATE OFFICES Beijing Moscow Boston Munich Brussels New York Century City Orange County Chicago Paris Dubai Riyadh Düsseldorf San Diego Frankfurt San Francisco November 1, 2021 Hamburg Seoul Hong Kong Shanghai Houston Silicon Valley London...dMY Technology Group, Inc. IV • November 1st, 2021 • Radio & tv broadcasting & communications equipment
We have acted as special tax counsel to Planet Labs, Inc., a Delaware corporation (“Company”), in connection with the Agreement and Plan of Merger, dated as of July 7, 2021 (the “Merger Agreement”), by and among dMY Technology Group, Inc., a Delaware corporation (“Parent”), Photon Merger Sub, Inc., a Delaware corporation and direct, wholly-owned subsidiary of Parent (“Merger Sub I”), Photon Merger Sub Two, LLC, a Delaware limited liability company and a direct, wholly-owned subsidiary of Parent (“Merger Sub II”), and Company. This opinion is being delivered in connection with the registration statement on Form S-4, filed with the Securities and Exchange Commission, as amended and supplemented through the date hereof (the “Registration Statement”), of Parent, including the proxy statement/prospectus forming a part thereof (the “Proxy Statement/Prospectus”), relating to the transactions contemplated by the Merger Agreement. Capitalized terms not defined herein have the meanings specified
