Exhibit 5.2


                                                      [Effective Date of Filing]

                                             [Letterhead of Pepper Hamilton LLP]

                                                                 January 8, 2002

Capsule Communications, Inc.
3331 Street Road, Suite 275
Two Greenwood Square
Bensalem, Pennsylvania 19020


Ladies and Gentlemen:

                  We have acted as counsel to Capsule Communications, Inc., a
Delaware corporation (the "Target"), in connection with the transactions
contemplated by the Agreement and Plan of Reorganization dated as of July 17,
2001 (the "Agreement"), by and among Target, Covista Communications, Inc., a New
Jersey corporation ("Acquiror"), and CCI Acquisitions Corp., a Delaware
corporation and a direct wholly owned subsidiary of Acquiror ("Merger Sub").
Unless otherwise defined, capitalized terms used herein have the meanings
assigned to them in the Agreement or in the Proxy Statement/Prospectus (the
"Proxy Statement/Prospectus") which will be included in the Registration
Statement on Form S-4 (the "Registration Statement") filed by Acquiror with the
Securities and Exchange Commission (the "Commission"). This opinion is being
furnished in accordance with the requirements of Item 601(b)(8) of Regulation
S-K of the Securities Act of 1933, as amended (the "Act").

                  In delivering this opinion, we have reviewed and relied upon
facts and descriptions set forth in the Registration Statement, the Agreement
and related documents pertaining to the Merger. We also have relied upon
certificates of officers of Acquiror and the Target (the "Officers'
Certificates"). We have assumed that the Officers' Certificates, respectively,
have been executed and delivered by appropriate officers of Acquiror and the
Target and are true and correct without any qualification as to knowledge and
belief. We also have assumed that the certifications made in the Officers'
Certificates, respectively, will continue to be true and correct as of the
Effective Time of the Merger unless we receive written notification from
Acquiror or the Target prior to the Effective Time of the Merger.

                  Based on the foregoing and the Internal Revenue Code of 1986,
as amended (the "Code"), the Income Tax Regulations issued by the United States
Treasury Department thereunder, rulings of the Internal Revenue Service and
court decisions, all as in effect on the date hereof, we are of the opinion that
if the Merger is completed in accordance with the terms and conditions of the
Agreement, and if the statements set forth in the Officers' Certificates are






Capsule Communications, Inc.
[Effective Date of Filing]
Page 2


true and correct on the date hereof and at the Effective Time of the Merger, for
United States federal income tax purposes:

         1.       The Merger will qualify as a reorganization within the meaning
                  of Section 368(a) of the Code.

         2.       Acquiror, Merger Sub, and the Target each will be a "party to
                  the reorganization" within the meaning of Section 368(b) of
                  the Code.

         3.       Except for items as to which we specifically express no
                  opinion, the discussion entitled "Tax Consequences of the
                  Merger Generally" in the Proxy Statement/Prospectus, insofar
                  as it relates to statements of law or legal conclusions, is
                  correct in all material respects. We hereby adopt such
                  discussion as our opinion, except as to the items as to which
                  no opinion is expressed.

         Our opinion does not address U.S. federal income tax consequences which
may vary with, or are contingent upon, a shareholder's individual circumstances.
In addition, our opinion does not address any non-income tax or any foreign,
state or local tax consequences of the Merger.

         In accordance with customary practice relating to opinion letters, our
opinion speaks only as of the date hereof, and, subject to the assumptions and
conditions set forth above, the Effective Time of the Merger, and we disclaim
any duty to update such opinion.

         Moreover, our opinion is based on the Internal Revenue Code of 1986,
as amended, applicable Treasury regulations promulgated thereunder, and
Internal Revenue Service rulings, procedures, and other pronouncements
published by the United States Internal Revenue Service. These authorities
are all subject to change, and such change may be made with retroactive
effect. We can give no assurance that, after such change, our opinion would
not be different. This opinion is not binding on the Internal Revenue
Service, and there can be no assurance, and none is hereby given, that the
Internal Revenue Service will not take a position contrary to one or more of
the positions reflected in the foregoing opinion, or that our opinion will be
upheld by the courts if challenged by the Internal Revenue Service.

         In accordance with requirements of Item 601(b)(23) of Regulation S-K
under Act, we hereby consent to the filing of this opinion with the Commission
as an exhibit to the Registration Statement at the time of the filing thereof,
and to the references made to us under the captions "Material United States
Federal Income Tax Consequences" and "Legal Matters" in the Proxy
Statement/Prospectus. In giving such consent, we do not thereby admit that we
are in the category of persons whose consent is required under Section 7 of
the Act.

                                                 Very truly yours,

                                                 /s/ Pepper Hamilton LLP

                                                 PEPPER HAMILTON LLP