EXHIBIT 8.2


                        [Letterhead of Perkins Coie LLP]

                                November 7, 2002



Ostex International, Inc.
2203 Airport Way, South, Suite 400
Seattle, WA  98134


         RE: ACQUISITION BY INVERNESS MEDICAL INNOVATIONS, INC.

Ladies and Gentlemen:

         This opinion is being delivered to you in accordance with Section
7.2(e) of the Agreement and Plan of Merger dated as of September 6, 2002 (the
"Merger Agreement") by and among Inverness Medical Innovations, Inc., a Delaware
corporation ("Inverness"), Geras Acquisition, Corp, a Washington corporation and
a wholly owned subsidiary of Inverness ("MergerCo"), and Ostex International,
Inc., a Washington corporation ("Ostex"). Unless otherwise indicated,
capitalized terms used herein have the meaning ascribed to them in the Merger
Agreement.

         In delivering this opinion, we have examined and relied upon originals
or copies, certified or otherwise identified to our satisfaction, of (i) the
Merger Agreement, (ii) the Registration Statement on Form S-4 filed with the
United States Securities and Exchange Commission (the "Commission") under the
Securities Act of 1933, as amended (the "Securities Act"), on November 7, 2002
(the "Registration Statement"), which Registration Statement includes the Proxy
Statement/Prospectus, and (iii) such other documents, certificates and records
as we have deemed necessary or appropriate. In addition, we have relied upon,
and assumed as true, correct, and complete at all relevant times, without any
independent investigation, (i) the statements, covenants, representations and
warranties contained in the Merger Agreement (including all schedules and
exhibits thereto); and (ii) the statements contained in the Registration
Statement and the representation letters delivered to us by Inverness, MergerCo,
and Ostex pursuant to the Merger Agreement (the "Tax Representation Letters").





Ostex International, Inc.
November 7, 2002
Page 2



         We have also assumed, without any independent investigation, (i) the
authenticity of original documents submitted to us, the conformity to the
originals of documents submitted to us as copies, and the due and valid
execution and delivery of all such documents where due execution and delivery
are a prerequisite to the effectiveness thereof; (ii) the performance of all
covenants contained in the Merger Agreement and the Tax Representation Letters
without waiver or breach of any material provision thereof; and (iii) the
accuracy of any representation or statement "to the best knowledge" or similarly
qualified without such qualification.

         Based upon the foregoing, and subject to the limitations,
qualifications, assumptions and caveats set forth herein, we are of the opinion
that the Merger will qualify as a reorganization within the meaning of Section
368(a) of the Internal Revenue Code of 1986, as amended (the "Code").

         Furthermore, based upon the foregoing and subject to the limitations
and qualifications set forth herein, we are of the opinion that under current
United States federal income tax law, the discussion set forth in the
Registration Statement under the heading "Material Federal Income Tax
Consequences," to the extent it describes legal matters or legal conclusions, is
accurate in all material respects.

         Our opinion herein is based on, as of the date hereof, the applicable
provisions of the Code, Treasury Regulations promulgated or proposed thereunder,
current positions of the Internal Revenue Service contained in published revenue
rulings, revenue procedures and announcements, pertinent judicial authorities
and other applicable authorities, all of which are subject to change either
prospectively or retroactively. No assurance can be given that future
legislative, judicial or administrative changes, on either a prospective or
retroactive basis, would not adversely affect the accuracy of our opinion.

         This opinion is expressed as of the date hereof, and we undertake no
responsibility to advise you of any subsequent changes of the facts stated or
assumed herein, or of any new developments in the application or interpretation
of the federal income tax laws. In the event any one of the statements,
representations, warranties or assumptions upon which we have relied to issue
this opinion is incorrect, our opinion might be adversely affected and may not
be relied upon. This opinion addresses only the matters described above, and
does not address any other federal state, local or foreign tax consequences that
may result from the Merger.





Ostex International, Inc.
November 7, 2002
Page 3



         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the captions "LEGAL
MATTERS" and "Material Federal Income Tax Consequences" in the Registration
Statement. 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, nor do we admit that we are experts with respect to any part of the
Registration Statement within the meaning of the term "expert" as used in the
Securities Act.

                                                     Very truly yours,

                                                     /s/ PERKINS COIE LLP

                                                     PERKINS COIE LLP