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                                                                     Exhibit 8.1



                        [COOLEY GODWARD LLP LETTERHEAD]



February 12, 1997

Allergan, Inc.
Allergan Specialty Therapeutics, Inc.
2525 Dupont Drive
Irvine, CA 92612

Dear Sir or Madam:

We have acted as United States tax counsel to Allergan, Inc., a Delaware
corporation ("Allergan"), and Allergan Specialty Therapeutics, Inc., a Delaware
corporation ("ASTI"), in connection with the Distribution Agreement to be
entered into between Allergan and ASTI (the "Agreement"). Unless otherwise
noted, capitalized terms used herein shall have the same respective meanings
given to them in the Agreement.

You have asked us to review the discussion of federal income tax issues
contained in Allergan and ASTI's Form S-1 Registration Statement filed in
connection with the Agreement (the "Registration Statement"). We have reviewed
the discussion entitled "Certain Federal Income Tax Considerations" contained
in the Registration Statement and are of the opinion that, subject to the
qualifications and limitations contained therein, such information fairly
presents the current federal income tax law applicable to the Agreement and the
material federal tax consequences to Allergan, ASTI and certain holders of ASTI
Shares that hold the ASTI Shares as capital assets as a result of the Agreement
and insofar as it relates to statements of law or legal conclusions is correct
in all material respects.

We consent to the reference to our firm under the caption "Certain Federal
Income Tax Considerations" included in the Registration Statement and to the
filing of this opinion as an exhibit to the Registration Statement.

Very truly yours,

Cooley Godward LLP



By: /s/ WEBB B. MORROW III
   ------------------------------
   Webb B. Morrow III

SCP/dp