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                                                                     EXHIBIT 8.1


                      [Letterhead of Dorsey & Whitney LLP]

                                August ___, 1999

ARIS Corporation
fine.com International Corp.

      RE:   Federal Income Tax Consequences of Merger of fine.com International
            with and into ARIS Interactive, Inc. a wholly owned subsidiary of
            ARIS Corporation

Ladies and Gentlemen:

            We have acted as special counsel to ARIS Corporation ("Acquiror"), a
Washington corporation, in connection with the merger of fine.com International
Corporation, a Washington corporation ("Target") with and into ARIS Interactive,
Inc., a Washington corporation ("Acquiror Sub"), a wholly owned subsidiary of
Acquiror, pursuant to that certain Agreement and Plan of Merger dated as of May
17, 1999 and amended and restated as of August [3], 1999 (by and among Acquiror,
Acquiror Sub, Target and certain Target shareholders (the "Merger Agreement").
In accordance with the Merger Agreement, we are rendering the following opinion
to Acquiror and to the Target. Unless otherwise provided herein, the capitalized
terms used herein shall have the meaning as set forth and explained in the
Merger Agreement.

            At the Effective Time of the Merger and pursuant to the Merger
Agreement, Target will be merged with and into Acquiror Sub and the separate
existence of Target will cease. Pursuant to the Merger, each Target Share issued
and outstanding at the Effective Time of the Merger (other than any shares as to
which statutory dissenters' appraisal rights have been exercised) will be
converted into the right to receive Acquiror Shares or a combination of Acquiror
Shares and cash, as described in the Merger Agreement.


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            Acquiror has asked for our opinion concerning certain federal income
tax consequences of the Merger. For purposes of rendering this opinion, we have
examined the Merger Agreement and such other instruments and documents as we
have deemed necessary or appropriate, and we have reviewed such questions of law
as we have considered necessary or appropriate.

            Our opinion is based upon the existing provisions of the Internal
Revenue Code of 1986, as amended (the "Code"), the current Treasury Department
Regulations issued thereunder, the current published administrative positions of
the Internal Revenue Service contained in revenue rulings, revenue procedures
and other administrative pronouncements, and judicial decisions, all of which
are subject to change prospectively and retroactively. Any change in such
authorities may affect the opinions rendered herein. We undertake no
responsibility to advise you of any new developments in the application or
interpretations of the federal income tax laws.

            In rendering this opinion, we have relied upon the statements,
descriptions, representations and warranties set forth in the Merger Agreement
and the representations set forth in the Certificates of even date herewith
delivered to us by Acquiror, Acquiror Sub, Target and certain Target
shareholders (the "Certificates") and no actions have been (or will be taken)
which are inconsistent with such statements, descriptions, representations and
warranties. In connection with rendering this opinion, we have assumed that any
statement made in the Merger Agreement, the Certificates or related documents
"to the best of knowledge", "to the knowledge", "to the belief" or similar
phrases of any person or party is correct without such qualification. Our
opinion is also based on the assumption that the parties to the Merger Agreement
will at all times comply with the terms of the Merger Agreement and that the
Merger will be consummated in the manner described therein.

            An opinion of counsel is predicated upon all the facts and
conditions set forth in this opinion and is based upon counsel's analysis of the
statutes, regulatory interpretations and case law in effect as of the date of
the opinion. It is not a guarantee of the current status of the law and should
not be accepted as a guarantee that a court of law or an administrative agency
will concur in the opinion.

            Based upon the foregoing, it is our opinion that the following
federal income tax consequences will result from the Merger:

            1. The Merger will qualify as a reorganization under Section 368(a)
      of the Code.


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            2. No gain or loss will be recognized by Acquiror, Acquiror Sub or
      Target as a result of the Merger.

            3. No gain or loss will be recognized by the shareholders of Target
      who exchange Target Shares for Acquiror Shares pursuant to the Merger,
      except with respect to any cash received by such Target shareholders in
      the Merger.

            4. Gain, if any, but not loss, will be recognized by Target
      shareholders upon the exchange of Target Shares for cash pursuant to the
      Merger. Such gain will be recognized, but not in excess of the amount of
      cash, in an amount equal to the difference, if any, between (a) the fair
      market value of the Acquiror Shares and cash received and (b) the Target
      shareholder's adjusted tax basis in the Target Shares surrendered in
      exchange therefor pursuant to the Merger. If the receipt of cash payments
      has the effect of a distribution of a dividend to a Target Shareholder,
      some or all of the gain recognized will be treated as a dividend taxed as
      ordinary income. If the exchange does not have the effect of a
      distribution of a dividend, all of the gain recognized would be a capital
      gain, provided the Target Shares are a capital asset in the hands of the
      Target shareholder at the time of the Merger.

            5. The aggregate tax basis of the Acquiror Shares received by a
      Target shareholder who exchanges Target Shares in the Merger will be the
      same as the aggregate tax basis of the Target Shares surrendered in
      exchange therefor, decreased by the amount of any cash received by such
      Target shareholder which is treated as a redemption rather than a dividend
      and increased by the amount of any non-dividend gain recognized by such
      Target Shareholder in connection with the Merger.

            6. The holding period of the Acquiror Shares received by a Target
      shareholder pursuant to the Merger will include the period during which
      the Target Shares surrendered therefor were held, provided the Target
      Shares are a capital asset in the hands of the Target shareholder at the
      time of the Merger.

            7. A Target shareholder who receives cash in lieu of a fractional
      share interest in Acquiror Shares will recognize gain or loss measured by
      the difference between the amount of cash received and the portion of the
      adjusted tax basis in the Target Shares allocable to the fractional share
      interest. Such gain or loss recognized would generally be a capital gain
      or loss, provided the Target Shares are a capital asset in the hands of
      the Target shareholder at the time of the merger. However, if the receipt
      of cash in lieu of a fractional share interest is essentially equivalent
      to a dividend to that Target shareholder, some or all of the gain
      recognized will be treated as a dividend taxed as ordinary income.


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            This opinion is expressed as of the date hereof, and we are under no
obligation to supplement or revise our opinion to reflect any changes (a) in
applicable law or (b) in any information, document, corporate record, covenant,
statement, representation, assumption or other matter stated herein which
becomes untrue or incorrect.

            Our opinion is limited to the matters expressly addressed in the
seven (7) numbered paragraphs above. No opinion is expressed and none should
be inferred as to any other matter, including, without limitation, whether any
cash payment to any Target shareholder qualifies as a redemption or dividend.
In addition, our opinion does not address transactions effectuated prior to or
after the Merger, whether or not such transactions are in connection with the
Merger.

                                          Very truly yours,








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