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                         [COOLEY GODWARD LLP LETTERHEAD]



November 17, 2000



Newgen Results Corporation
12680 High Bluff Drive
Suite 300
San Diego, California  92130


Ladies and Gentlemen:

This opinion is being delivered to you in connection with the filing of a
registration statement (the "Registration Statement") on Form S-4, which
includes the Proxy Statement and Prospectus relating to the Agreement and Plan
of Merger dated as of August 21, 2000 (the "Reorganization Agreement") by and
among TeleTech Holdings, Inc., a Delaware corporation ("Parent"), NG Acquisition
Corp., a Delaware corporation and wholly owned subsidiary of Parent ("Merger
Sub"), and Newgen Results Corporation, a Delaware corporation (the "Company").

Except as otherwise provided, capitalized terms used but not defined herein
shall have the meanings set forth in the Reorganization Agreement. All section
references, unless otherwise indicated, are to the Internal Revenue Code of
1986, as amended (the "Code").

We have acted as counsel to the Company in connection with the Merger. As such,
and for the purpose of rendering this opinion, we have examined, and are relying
upon (without any independent investigation or review thereof) the truth and
accuracy, at all relevant times, of the statements, covenants, representations
and warranties contained in the following documents (including all exhibits and
schedules attached thereto):

     (a)  the Reorganization Agreement;

     (b)  the Registration Statement;

     (c)  those certain tax representation letters dated November 17, 2000, and
delivered to us by Parent, Merger Sub and the Company (the "Tax Representation
Letters"); and

     (d)  such other instruments and documents related to the formation,
organization and operation of Parent, Merger Sub and the Company and to the
consummation of the Merger and the other transactions contemplated by the
Reorganization Agreement as we have deemed necessary or appropriate.

In connection with rendering this opinion, we have assumed (without any
independent investigation or review thereof) that:
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Newgen Results Corporation
November 17, 2000
Page Two


     (a)  Original documents submitted to us (including signatures thereto) are
authentic, documents submitted to us as copies conform to the original
documents, and that all such documents have been (or will be by the Effective
Time) duly and validly executed and delivered where due execution and delivery
are a prerequisite to the effectiveness thereof;

     (b)  All representations, warranties and statements made or agreed to by
Parent, Merger Sub and the Company, their managements, employees, officers,
directors and stockholders in connection with the Merger, including, but not
limited to, those set forth in the Reorganization Agreement (including the
exhibits thereto) and the Tax Representation Letters are true and accurate at
all relevant times;

     (c)  All covenants contained in the Reorganization Agreement (including
exhibits thereto) and the Tax Representation Letters are performed without
waiver or breach of any material provision thereof;

     (d)  The Merger will be reported by Parent and the Company on their
respective federal income tax returns in a manner consistent with the opinion
set forth below;

     (e)  The Merger will be consummated in accordance with the Reorganization
Agreement without any waiver or breach of any material provision thereof, and
the Merger will be effective under applicable state law;

     (f)  Any representation or statement made "to the knowledge of" or
similarly qualified is correct without such qualification; and

     (g)  The opinion rendered by Hogan & Hartson LLP to Parent has been
delivered and has not been withdrawn.

Based on our examination of the foregoing items and subject to the limitations,
qualifications, assumptions and caveats set forth herein, we are of the opinion
that, for federal income tax purposes, the Merger will be a reorganization
within the meaning of Section 368(a) of the Code.

In addition to your request for our opinion on this specific matter of federal
income tax law, you have asked us to review the discussion of federal income tax
issues contained in the Registration Statement. We have reviewed the discussion
entitled "Material United States Federal Income Tax Consequences of the Merger"
contained in the Registration Statement and believe that, insofar as it relates
to statements of law and legal conclusions, it sets forth the material United
States federal income tax considerations generally applicable to the Merger and
is correct in all material respects.
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Newgen Results Corporation
November 17, 2000
Page Three


This opinion does not address the various state, local or foreign tax
consequences that may result from the Merger or the other transactions
contemplated by the Reorganization Agreement and does not address the federal
tax consequences of any transaction other than the Merger as described in the
Reorganization Agreement. In addition, no opinion is expressed as to any federal
income tax consequence of the Merger or the other transactions contemplated by
the Reorganization Agreement except as specifically set forth herein, and this
opinion may not be relied upon except with respect to the consequences
specifically discussed herein.

No opinion is expressed as to any transaction whatsoever, including the Merger,
if any of the representations, warranties, statements and assumptions material
to our opinion and upon which we have relied are not accurate and complete in
all material respects at all relevant times.

This opinion only represents our best judgment as to the federal income tax
consequences of the Merger and is not binding on the Internal Revenue Service or
any court of law, tribunal, administrative agency or other governmental body.
The conclusions are based on the Code, existing judicial decisions,
administrative regulations and published rulings. No assurance can be given that
future legislative, judicial or administrative changes or interpretations would
not adversely affect the accuracy of the conclusions stated herein.
Nevertheless, by rendering this opinion, we undertake no responsibility to
advise you of any new developments in the application or interpretation of the
federal income tax laws.

This opinion is being delivered solely in connection with the Registration
Statement. It is intended for the benefit of the Company and may not be relied
upon or utilized for any other purpose or by any other person and may not be
made available to any other person without our prior written consent.

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Newgen Results Corporation
November 17, 2000
Page Four


We consent to the reference to our firm under the caption "Material United
States Federal Income Tax Consequences of the Merger" in the Proxy Statement
included in the Registration Statement and to the reproduction and filing of
this opinion as an exhibit to the Registration Statement.

Sincerely,

COOLEY GODWARD LLP

/s/ Robert H. Miller


