
<PAGE>   1
                                                                     EXHIBIT 8.2

                               [WSGR Letterhead]

                                  May 23, 2000




E-TEK Dynamics, Inc.
1865 Lundy Avenue
San Jose, CA 95131

     RE:  MERGER AMONG JDS UNIPHASE CORPORATION, A DELAWARE CORPORATION ("JDS
          UNIPHASE"), RAINBOW ACQUISITION, INC., A DELAWARE CORPORATION ("MERGER
          SUB"), AND E-TEK DYNAMICS, INC. ("E-TEK"), A DELAWARE CORPORATION

Ladies and Gentlemen:

     We have acted as counsel to E-TEK, a Delaware corporation, in connection
with the proposed merger (the "Merger") of JDS Uniphase's wholly-owned
transitory merger subsidiary, Merger Sub, with and into E-TEK pursuant to an
Agreement and Plan of Reorganization and Merger dated as of January 17, 2000
(the "Merger Agreement"). The Merger and certain proposed transactions incident
thereto are described in the Registration Statement on Form S-4 (the
"Registration Statement") of JDS Uniphase which includes the Proxy
Statement/Prospectus of JDS Uniphase and E-TEK (the "Proxy
Statement/Prospectus"). This opinion is being rendered pursuant to the
requirements of Item 21(a) of Form S-4 under the Securities Act of 1933, as
amended. Unless otherwise indicated, any capitalized terms used herein and not
otherwise defined have the meaning ascribed to them in the Proxy
Statement/Prospectus.

     In connection with this opinion, we have examined and are familiar with the
Merger Agreement, the Registration Statement, and such other presently existing
documents, records and matters of law as we have deemed necessary or appropriate
for purposes of our opinion. In addition, we have assumed (i) that the Merger
will be consummated in the manner contemplated by the Proxy Statement/Prospectus
and in accordance with the provisions of the Merger Agreement, (ii) the truth
and accuracy of the representations and warranties made by JDS Uniphase, E-TEK
and Merger Sub in the Merger Agreement, (iii) the truth and accuracy of the
certificates of representations to be provided to us by JDS Uniphase, E-TEK and
Merger Sub and (iv) the adoption of a Certificate of Designations of the Special
Voting Preferred Stock by E-TEK and the taking of any other actions necessary to
grant voting rights in E-TEK to the exchangeable Class A Shares of Lundy
Technology Co.

     Because this opinion is being delivered prior to the Effective Time of the
Merger, it must be considered prospective and dependent on future events. There
can be no assurance that changes in the law will not take place which could
affect the United States Federal income tax considerations of the Merger or that
contrary positions may not be taken by the Internal Revenue Service.

     Based upon and subject to the foregoing, in our opinion, the discussion
contained in the Registration Statement under the caption "Material U.S. Federal
Income Tax Considerations of the Merger," subject to the limitations and
qualifications described therein, sets forth the material United States Federal
income tax considerations generally applicable to the Merger.
<PAGE>   2

     This opinion is furnished to you solely for use in connection with the
Registration Statement. We hereby consent to the filing of this opinion as an
exhibit to the Registration Statement. We also consent to the reference to our
firm name wherever appearing in the Registration Statement with respect to the
discussion of the material federal income tax considerations of the Merger,
including the Proxy Statement/Prospectus constituting a part thereof, and any
amendment thereto. In giving this 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 of 1933, as amended, or the rules and regulations of the
Securities and Exchange Commission thereunder, nor do we thereby admit that we
are experts with respect to any part of such Registration Statement within the
meaning of the term "experts" as used in the Securities Act of 1933, as amended,
or the rules and regulations of the Securities and Exchange Commission
thereunder.

                                       Very truly yours,



                                       WILSON SONSINI GOODRICH & ROSATI
                                       Professional Corporation
