EXHIBIT 8.1 NIXON PEABODY LLP 437 Madison Avenue, 25th Floor New York, New York 10004 Telephone: (212) 940-3000 Facsimile: (212) 940-3111 BODMAN, LONGLEY & DAHLING LLP 100 Renaissance Center, 34th Floor Detroit, Michigan 48243 Telephone: (313) 259-7777 Facsimile: (313) 393-7579 April __, 2000 Board of Directors TekInsight.Com, Inc 5 Hanover Square, 24th Floor New York, New York 10004 Board of Directors Data Systems Network Corporation 34705 W. 12 Mile Road, Suite 300 Farmington Hills, Michigan 48331 Gentlemen: Nixon Peabody LLP is acting as special tax counsel to TekInsight.Com, Inc., a Delaware corporation ("TekInsight"), and TekInsight Services, Inc, a Delaware corporation and a wholly-owned subsidiary of TekInsight ("TekInsight Services"), in connection with the merger ("Merger") of Data Systems Network Corporation, Inc., a Michigan corporation ("Data Systems"), with and into TekInsight or with and into TekInsight Services pursuant to an Agreement and Plan of Merger, dated as of February 18, 2000, as amended April 4, 2000 ("Merger Agreement"), by and among TekInsight, TekInsight Services, and Data Systems. Bodman, Longley & Dahling LLP is acting as special tax counsel to Data Systems in the same transaction. This is our joint federal income tax opinion. TekInsight proposes to file a registration statement on Form S-4 ("Registration Statement") with the Securities and Exchange Commission under the Securities Act of 1933, as amended ("1933 Act"), SEC File Number 333- ______, with respect to the Series A preferred stock $0.01 par value of TekInsight to be issued to holders of shares of common stock, par value $0.01 per share, of Data Systems ("Data Systems Common Stock") in connection with the Merger. In addition, Data Systems has prepared, and we have reviewed, a proxy statement that is contained in and made a part of the Registration Statement ("Proxy Statement/Prospectus"). In rendering the opinion set forth below we have relied upon the facts stated in the Proxy Statement/Prospectus, upon such other documents as we have deemed appropriate, and representations of TekInsight and Data Systems in the Merger Agreement and otherwise referred to in the Proxy Statement/Prospectus. We confirm that our opinion as to the material federal income tax consequences of the Merger is as expressed in that section of the TekInsight.Com, Inc. Data Systems Network Corporation April 24, 2000 Page -2- Proxy/Statement Prospectus captioned "MATERIAL FEDERAL INCOME TAX CONSEQUENCES OF THE MERGER." Our opinion is subject to all of the assumptions, qualifications and limitations stated in the Proxy Statement/Prospectus (and including certain management representations that are assumed to be complete and accurate in all material respects to be provided by TekInsight and Data Systems to us prior to the effective time of the Merger). Each of our opinions is furnished to the board of directors of our respective clients solely for use in connection with the Registration Statement. Our opinion may not be used for any other purpose without our prior written consent. We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference to our firms under the caption "Legal Matters" in the Registration Statement. 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 1933 Act. Very truly yours, NIXON PEABODY LLP Very truly yours, BODMAN, LONGLEY & DAHLING LLP