EXHIBIT 8.2

                            OPINION OF KINSTON SMITH


                             Devonshire House
                             60 Goswell Road
                             London
                             EC1M 7AD

                                                                19 October 2000

Starnet Communications International (DE) Inc.
The CIBC Centre
Old Parham Road
PO Box 3265
St. John's
Antigua
West Indies

World Gaming Plc
Devonshire House
60 Goswell Road
London
EC1M 7AD


Dear Sirs:

STARNET COMMUNIATIONS INTERNATIONAL (DE) INC - REPLACEMENT BY A UK HOLDING
COMPANY

We have acted as tax advisers in the UK to World Gaming Plc ("Holdings") and
Starnet Communications International (DE) Inc. ("the Company") in connection
with the proposed replacement of Starnet Communications International (DE) Inc
as the holding company by Holdings as more fully described in the Registration
Statement (as defined below).

For the purposes of giving this opinion, we have examined the registration
statement on Form F-4 proposed to be filed with the US Securities and
Exchange Commission (the "Registration Statement", which term does not
include any exhibits thereto or any documents incorporated therein by
reference) on 19th October 2000 in respect of ordinary shares of Holdings, par
value 1 pence each, to be issued in the proposed merger and reorganisation
(the "Shares"). We have also reviewed copies of the Agreement and Plan of
Reorganisation and such other documents and made such enquiries as to
questions of law as we have deemed necessary in order to render the opinion
set forth below.

We have assumed (a) the genuineness and authenticity of all signatures and
the conformity to the originals of all copies of documents (whether or not
certified), (b) the accurateness and completeness of all factual
representations made in the Registration Statement and other documents
reviewed by us, (c) that upon the merger of the Company and WG Reorganization
Sub, Inc., a Delaware corporation and indirect, wholly-owned subsidiary of
Holdings, the Shares will be duly authorised, validly issued, fully paid and



non-assessable (the term non-assessable when used herein means only that the
holders of Shares cannot be assessed for or required to make additional capital
contributions by virtue of their ownership of the Shares) and (d) that there is
no provision of the law of any jurisdiction, other than English Law, which would
have any implication in relation to the opinions expressed herein.

We have made no investigation of and express no opinion in relation to the
laws of any jurisdiction other than that of England. This opinion is governed
by and construed in accordance with the laws of England and is limited to and
is given on the basis of the current law in practice in England.

On the basis of, and subject to, the foregoing, we are of the opinion that
the statements in the Registration Statement under the heading "United
Kingdom Tax Consequences" to the extent that they constitute matters of
United Kingdom domestic tax law, or English law conclusions, are accurate in
all material respects.

In addition it is issued on the basis that there are no employees of the
group who are liable to any UK taxation in respect of the performance of any
of their employment duties.

Subject as above we hereby consent to the filing of this opinion as an
exhibit to the Registration Statement and the reference to our firm under the
section "United Kingdom Tax Consequences".

                                      Yours faithfully,

                                      /s/ Kingston Smith