Exhibit 8.1

[KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS LOGO]


                             200 East Randolph Drive
                             Chicago, Illinois 60601

                                 312 861-2000                   Facsimile:
                                                               312 861-2200

                                www.kirkland.com


                               September 9, 2004


Prestige Brands, Inc.
and the Guarantors set forth on Exhibit A
90 North Irvington, New York  10533
(914) 524-6810

          Re:  REGISTRATION STATEMENT ON FORM S-4 (REGISTRATION NO. 333-117152)


Ladies and Gentlemen:

     We are issuing this opinion letter in our capacity as special legal counsel
to Prestige Brands, Inc., a Delaware corporation (the "Issuer"), and the
guarantors set forth on Exhibit A hereto (the "Guarantors" and, collectively
with the Issuer, the "Registrants"). This opinion letter is being delivered in
connection with the proposed registration by the Issuer of $210,000,000 in
aggregate principal amount of the Issuer's 9 1/4% Senior Subordinated Notes due
2012, Series B (the "Exchange Notes") pursuant to a Registration Statement on
Form S-4 (Registration No. 333-117152) as filed with the Securities and Exchange
Commission (the "Commission") on the date hereof, under the Securities Act of
1933, as amended (the "Act") (such Registration Statement, as amended or
supplemented, is hereinafter referred to as the "Registration Statement").

     You have requested our opinion as to certain United States federal income
tax consequences of participating in the exchange offer for Exchange Notes
described in the Registration Statement. Our opinion, under the law in effect on
the date hereof, is set forth in the statements made in the Registration
Statement under the caption "Material United States Federal Income Tax
Consequences - United States Holders - Exchange Offer."

     The opinion set forth therein is based on the applicable provisions of the
Internal Revenue Code of 1986, as amended; the Treasury Regulations promulgated
or proposed thereunder; current positions of the Internal Revenue Service (the
"IRS") contained in published revenue rulings, revenue procedures and
announcements; existing judicial decisions; and other applicable authorities,
all of which are subject to change, possibly with retroactive effect.

     Unlike a ruling from the IRS, opinions of counsel are not binding on the
IRS. Hence, no assurance can be given that the opinion stated in the
Registration Statement will not be successfully challenged by the IRS or
rejected by a court. We express no opinion concerning any Federal income tax
matter other than those discussed in the Registration Statement under the

London     Los Angeles     New York        San Francisco       Washington, D.C.



caption "Material United States Federal Income Tax Consequences - United States
Holders - Exchange Offer."

     We hereby consent to the filing of this opinion with the commission as
Exhibit 8.1 to the Registration Statement. We also consent to the reference to
our firm under the heading "Legal Matters" 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 Act or the rules and
regulations of the Commission.

                                                    Sincerely,

                                                    /s/ Kirkland & Ellis LLP

                                                    Kirkland & Ellis LLP



                                    EXHIBIT A

Prestige Brands International, LLC
Prestige Household Holdings, Inc.
Prestige Household Brands, Inc.
The Comet Products Corporation
The Spic and Span Company
Prestige Products Holdings, Inc.
Prestige Acquisition Holdings, LLC
Bonita Bay Holdings, Inc.
Prestige Brands Holdings, Inc.
Prestige Brands International, Inc.
Prestige Brands Financial Corporation
Medtech Holdings, Inc.
Medtech Products Inc.
Pecos Pharmaceutical, Inc.
The Cutex Company
Prestige Personal Care Holdings, Inc.
Prestige Personal Care, Inc.
The Denorex Company