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                                                                     EXHIBIT 8.2
                      [MORRISON & FOERSTER LLP LETTERHEAD]


                                October 14, 1999



SMART Modular Technologies, Inc.
4305 Cushing Parkway
Fremont, CA  94304-1050

Ladies and Gentlemen:

We have acted as counsel to SMART Modular Technologies, Inc. ("SMART Modular"),
a California corporation, in connection with the proposed merger (the "Merger")
of SM Acquisition Corp. ("SMAC"), a California corporation and a direct
wholly-owned transitory merger subsidiary of Solectron Corporation
("Solectron"), a Delaware corporation, with and into SMART Modular pursuant to
an Agreement and Plan of Merger dated as of September 13, 1999 (the "Merger
Agreement"). The Merger is described in the Registration Statement of Solectron
on Form S-4 (the "Registration Statement") filed on the date hereof with the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933, as amended (the "Securities Act"), which includes the joint proxy
statement and prospectus of SMART Modular and Solectron (the "Proxy
Statement/Prospectus").

In that connection, we have reviewed the Merger Agreement, the Proxy
Statement/Prospectus and such other materials 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 accordance with the provisions of the Merger
Agreement and as contemplated by the Proxy Statement/Prospectus and (ii) the
truth and accuracy, on the date of the Merger Agreement and on the date hereof,
of the representations and warranties made by Solectron, SMAC and SMART Modular
in the Merger Agreement.

Based upon and subject to the foregoing, in our opinion, the discussions
contained in the Registration Statements under the caption "Material United
States Federal Income Tax Considerations of the Merger," subject to the
limitations and qualifications described therein, set

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SMART Modular Technologies, Inc.
October 14, 1999
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forth the material United States Federal income tax considerations generally
applicable to the Merger. Because this opinion is being delivered prior to the
effective time of the Merger, it must be considered prospective and dependent
upon future events. There can be no assurance that changes in the law will not
take place which could affect the Federal income tax consequences of the Merger
or that contrary positions may not be asserted by the Internal Revenue Service.

This opinion is being furnished in connection with the Registration Statement.
You may rely upon and refer to the foregoing opinion in the Proxy
Statement/Prospectus. Any variation or difference in any fact from those set
forth or assumed either herein or in the Proxy Statement/Prospectus may affect
the conclusions stated herein.

We hereby consent to the use of our name under the caption "Material United
States Federal Income Tax Considerations of the Merger" in the Proxy
Statement/Prospectus and to the filing of this opinion as an Exhibit to the
Registration Statement. In giving this consent, we do not admit that we come
within the category of persons whose consent is required under Section 7 of the
Securities Act or the rules and regulations of the Commission thereunder.



                                            Very truly yours,



                                            /s/ Morrison & Foerster LLP
                                            ---------------------------
                                            Morrison & Foerster LLP