
<PAGE>

                                                                   EXHIBIT 8.2


               [TROY & GOULD PROFESSIONAL CORPORATION LETTERHEAD]

   
                               September 14, 1998
    



Eltron International, Inc.
41 Moreland Road
Simi Valley, CA 93065


     Re: ELTRON MERGER--CERTAIN FEDERAL INCOME TAX CONSEQUENCES


Ladies and Gentlemen:


     We have acted as your counsel in connection with the Agreement and Plan 
of Merger dated as of July 9, 1998 (the "Merger Agreement"), by and among 
Eltron International, Inc., a California corporation (the "Company"), Zebra 
Technologies Corporation, a Delaware corporation ("Parent"), and Spruce 
Acquisition Corp., a California corporation ("Merger Sub"), and the 
preparation of the Proxy Statement accompanying the Notice of Special Meeting 
of Shareholders of the Company to be held on October __, 1998.

     This opinion is being furnished to you pursuant to Section 7.1(h) of the 
Merger Agreement.  In rendering our opinion, we have considered and relied 
upon the provisions of the Internal Revenue Code of 1986, as amended (the 
"Code"), the Treasury Regulations promulgated thereunder, published 
administrative rulings and judicial decisions, such other authorities as we 
have deemed appropriate, and representations contained in representation
<PAGE>

   
Eltron International, Inc.
September 14, 1998
Page 2
    

letters of the Company and Parent (in the form of Exhibits D-1 and D-2 of the 
Merger Agreement).

     We have examined and are familiar with originals or copies, certified or 
otherwise identified to our satisfaction, of (i) the Merger Agreement 
(including all exhibits thereto); (ii) the Proxy Statement; (iii) the 
Affiliate Agreements entered into by the executive officers and directors of 
the parties to the merger of the Company and Merger Sub; (iv) the 
Stockholders Agreement dated July 9, 1998; and (v) such other documents as we 
have deemed necessary or appropriate as a basis for the opinion set forth 
below.  As to any facts material to this opinion which we did not 
independently establish or verify, we have relied upon the Proxy Statement 
and statements and representations contained in the representation letters 
referred to above.  Capitalized terms not otherwise defined herein shall have 
the meanings assigned to them in the Proxy Statement.

     The particular aspect of the Merger Agreement with respect to which our 
opinion is requested involves the merger of the Company, a publicly traded 
corporation, into Merger Sub, a newly-formed, wholly-owned subsidiary of 
Parent, with the Company to be the surviving corporation (the "Merger").  
Merger Sub has no significant liabilities or tangible assets and will have no 
significant liabilities or tangible assets as of the time of the Merger.  
Each share of Company Common Stock (the Company Common Stock being the sole 
class of outstanding stock of the Company) will be converted into .9 share of 
Parent Common Stock pursuant to the Merger.  The Merger Agreement recited 
that the Boards of Directors of the parties thereto believe the Merger to be 
in the best interests of Parent and the Company and the Proxy Statement sets 
forth the business purposes for the Merger.  This opinion is limited solely 
to the Merger.
<PAGE>

   
Eltron International, Inc.
September 14, 1998
Page 3
    

     In addition to the disclosure in the Proxy Statement, the 
representations in the Merger Agreement and in the Affiliate Agreements, upon 
which we rely, we have relied on the representations made in the 
representation letters of Parent and the Company substantially in the form of 
Exhibits D-1 and D-2 of the Merger Agreement.
   
     Based upon and subject to the foregoing and assuming that there are no 
changes in the material facts relating to the Merger, that the foregoing 
agreements are performed in accordance with their terms as of the date hereof 
and that the representations referred to above remain in effect through the 
consummation of the Merger, we are of the opinion that the Merger would 
qualify for nonrecognition treatment under the Code, with the following 
federal income tax consequences:
    
     (a)  The Company will recognize no gain or loss in the Merger;

     (b)  No gain or loss will be recognized by holders of Company Common 
Stock upon their receipt of Parent Common Stock in exchange for their Company 
Common Stock in the Merger;

     (c)  The aggregate tax basis of the Parent Common Stock received in the 
Merger by the holders of Company Common Stock will be the same as the 
aggregate tax basis of the Company Common Stock exchanged therefor;

     (d)  The holding period of the Parent Common Stock received in the 
Merger will include the period for which the Company Common Stock surrendered 
in exchange therefor was held, provided that the Company Common Stock was 
held as a capital asset at the time of the Merger;
<PAGE>

   
Eltron International, Inc.
September 14, 1998
Page 4
    

     (e)  A holder of Company Common Stock who receives cash in lieu of 
fractional shares of Parent Common Stock will be treated as having received 
such fractional shares pursuant to the Merger and then as having exchanged 
such fractional shares for cash in a redemption by Parent.  Any gain or loss 
attributable to fractional shares will generally be capital gain or loss.  
The amount of such gain or loss will be equal to the difference between the 
cash received and the ratable portion of the tax basis of the Company Common 
Stock allocated to such fractional shares.  Any such gain or loss will 
constitute long-term gain or loss, subject to a maximum tax rate of 28% for 
noncorporate taxpayers, if such Company Common Stock has been held for more 
than one year (but not more than 18 months) at the time of consummation of 
the Merger and a maximum rate of 20% for noncorporate taxpayers if held for 
more than 18 months at the time of the consummation of the Merger; and

     (f)  A holder of Company Common Stock who exercises dissenters' rights 
and receives payment for a share of Company Common Stock in cash will 
generally recognize gain or loss for federal income tax purposes, measured by 
the difference between the holder's basis in such share and the amount of 
cash received, provided that the payment is neither "essentially equivalent 
to a dividend" within the meaning of Section 302 of the Code nor has the 
effect of a distribution of a dividend within the meaning of Section 
356(a)(2) of the Code (collectively, a "Dividend Equivalent Transaction").
A sale of Company Common Stock pursuant to an exercise of dissenters' rights 
will generally not be a Dividend Equivalent Transaction if, as a result of 
such exercise, the shareholder exercising dissenters' rights owns no shares 
of Parent Common Stock (either actually or constructively, as provided in 
Section 318 of the Code).  If, however, a shareholder's sale for cash of 
Company Common Stock pursuant to an exercise of dissenters' rights is 
<PAGE>

   
Eltron International, Inc.
September 14, 1998
Page 5
    

deemed to be a Dividend Equivalent Transaction, then such shareholder will 
generally recognize income for federal income tax purposes in an amount up to 
the entire amount of the cash so received.

     Except as set forth above, we express no opinion as to any federal, 
state, local or foreign tax consequences.  The statutory provisions, 
regulations, interpretations and other authorities on which our opinion is 
based are subject to change and any such change could apply retroactively.  
In addition, there can be no assurance that positions contrary to those stated
in our opinion will not be taken by the Internal Revenue Service.

     We consent to the use of this opinion as an exhibit to the Proxy 
Statement and to the reference to our views under the caption "Experts" in 
the Proxy Statement.  This opinion may not otherwise be used, circulated, 
quoted or referred to without our express written consent.


                                   Very truly yours,

   
                                   /s/ Troy & Gould Professional Corporation
    
                                   TROY & GOULD
                                   PROFESSIONAL CORPORATION
