EXHIBIT 8.1

                  [LETTERHEAD OF SONNENSCHEIN NATH & ROSENTHAL]


November 5, 2001

Mediacom Broadband LLC
Mediacom Broadband Corporation
100 Crystal Run Road
Middletown, New York 10941

Dear Gentlemen:

         We are counsel to Mediacom Broadband LLC, a Delaware limited liability
company, and Mediacom Broadband Corporation, a Delaware corporation
(collectively, the "Issuers"), which have requested that we render an opinion in
connection with a Registration Statement on Form S-4 heretofore filed by the
Issuers (the "Registration Statement"), covering the registration of
$400,000,000 aggregate principal amount of 11% Senior Notes due 2013 (the
"Exchange Notes") to be offered in exchange for (the "Exchange Offer") all of
the Issuers' outstanding 11% Senior Notes due 2013 (the "Initial Notes").

         We have made such examination as we have deemed necessary and
appropriate for the purpose of this opinion. Based on the terms of the Exchange
Offer, the Initial Notes, and the Exchange Notes as described in the
Registration Statement, it is our opinion that the summary set forth in the
Registration Statement under the heading "U.S. Federal Tax Considerations"
accurately describes the material United States federal tax consequences of the
Exchange Offer to the holders of the Initial Notes on the exchange of Initial
Notes for Exchange Notes. The summary does not purport to discuss all aspects of
United States federal taxation which may be relevant to particular holders of
the Initial Notes in light of such holders' personal circumstances.

         The foregoing opinion is based on current provisions of the Internal
Revenue Code of 1986, as amended, applicable Treasury regulations promulgated
thereunder, published pronouncements and other administrative interpretations by
the Internal Revenue Service, and case law, all of which are subject to change
at any time with retroactive effect. We undertake no obligation to update this
opinion in respect of any such changes.

         This opinion is solely for your benefit in connection with the matter
addressed herein, and may not be relied upon by you for any other purpose nor
furnished to, or relied upon by, any other person without our prior written
consent.

         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 caption "Legal
Matters" in the prospectus forming a part of the Registration Statement.

                                            Very truly yours,

                                            SONNENSCHEIN NATH & ROSENTHAL



                                            By:      /s/ Marc D. Teitelbaum
                                                     A Member of the Firm