Exhibit 8.1


                               February 14, 2002


Hewlett-Packard Company
3000 Hanover Street
Palo Alto, California 94304

Ladies and Gentlemen:

         We have acted as counsel to Hewlett-Packard Company, a Delaware
corporation ("HP"), in connection with the preparation and execution of the
Offer Agreement (the "Agreement"), dated as of September 6, 2001, by and among
HP and Indigo N.V., a corporation organized under the laws of the Netherlands
("Indigo"). Pursuant to the Agreement, Hewlett-Packard Erste
Vermogensverwaltungs- und Beteiligungsgesellschaft mbH, an indirect subsidiary
of HP ("Subsidiary"), will offer to acquire all of the outstanding common shares
of Indigo in exchange for either shares of HP common stock or a combination of
shares of HP common stock and contingent value rights entitling the holder to a
contingent cash payment from Subsidiary upon the achievement of certain
milestones (the "Exchange Offer"). The Exchange Offer and certain proposed
transactions incident thereto are described in the Registration Statement on
Form S-4 (the "Registration Statement") of HP, which includes the Prospectus
relating to the Exchange Offer (the "Prospectus"). This opinion is being
rendered pursuant to the requirements of Item 21(a) of Form S-4 under the
Securities Act of 1933, as amended. Unless otherwise indicated, any capitalized
terms used herein and not otherwise defined have the meaning ascribed to them in
the Agreement or the Registration Statement.

         In connection with this opinion, we have examined and are familiar with
the Agreement, the Registration Statement, and such other presently existing
documents, records and matters of law as we have deemed necessary or appropriate
for purposes of our opinion. In addition, we have assumed (i) that the Exchange
Offer will be consummated in the manner contemplated by the Prospectus and in
accordance with the provisions of the Agreement, (ii) the truth and accuracy of
all facts, statements, covenants, representations and warranties contained in
any of the documents referred to herein (including, without limitation, the
Agreement and the Registration Statement) or otherwise made to us, and (iii)
that Indigo is not a "passive foreign investment company" for United States
federal income tax purposes. This opinion is based on current United States
federal income tax law. There can be no assurance that changes in the law will
not take place that could affect the United States federal income tax
consequences of the Exchange Offer or that contrary positions may not be taken
by the Internal Revenue Service.

         Based upon and subject to the foregoing, this opinion confirms our
opinion set forth in the discussion contained in the Registration Statement
under the caption "Special Factors-- United States Federal Income Tax
Consequences of the Exchange Offer," subject to the limitations and
qualifications described therein.



Hewlett-Packard Company
February 14, 2002
Page 2

         This opinion is furnished to you solely for use in connection with the
Registration Statement. We hereby consent to the filing of this opinion as
Exhibit 8.1 to the Registration Statement. We also consent to the reference to
our firm name wherever appearing in the Registration Statement with respect to
the discussion of the material United States federal income tax consequences of
the Exchange Offer, including the Prospectus constituting a part thereof, and
any amendment thereto. 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 of 1933, as amended, or the rules and regulations of the
Securities and Exchange Commission thereunder, nor do we thereby admit that we
are experts with respect to any part of such Registration Statement within the
meaning of the term "experts" as used in the Securities Act of 1933, as amended,
or the rules and regulations of the Securities and Exchange Commission
thereunder.

                                       Very truly yours,

                                       /s/ Wilson Sonsini Goodrich & Rosati

                                       WILSON SONSINI GOODRICH & ROSATI
                                       Professional Corporation