Exhibit 8.1

October 12, 2007

ARRIS Group, Inc.
3871 Lakefield Drive
Suwanee, Georgia 30024

Ladies and Gentlemen:

     We have acted as counsel to ARRIS Group, Inc., a Delaware corporation (“ARRIS”), in connection with (i) the Agreement and Plan of Merger (the “Merger Agreement”), dated September 23, 2007, by and among ARRIS, Air Merger Subsidiary, Inc., a Delaware corporation (“Merger Sub”), and C-COR Incorporated, a Pennsylvania corporation (“C-COR”), pursuant to which C-COR will be merged with and into Merger Sub (the “Merger”) and (ii) the preparation and filing of the registration statement on Form S-4 to which this opinion letter is filed as an exhibit (the “Registration Statement”). All capitalized terms used but not defined herein shall have the meanings ascribed to them in the Merger Agreement.

     For purposes of the opinion set forth below, we have examined and relied upon the Merger Agreement, the Registration Statement, the Proxy Statement/Prospectus contained in the Registration Statement (the “Proxy Statement/Prospectus”), and such other documents as we have deemed necessary and appropriate for purposes of this opinion. In our examination of documents, we have assumed that all documents submitted to us as copies faithfully reproduce the original thereof, that such originals are authentic, that all such documents have been or will be duly executed to the extent required, and that all obligations imposed by any such documents on the parties thereto have been or will be performed or satisfied in accordance with their terms. In addition, we have obtained such additional information and representations as we have deemed relevant and necessary through consultation with various representatives of ARRIS, Merger Sub and C-COR, including written certificates (the “Certificates”) from officers of ARRIS, Merger Sub and C-COR verifying certain relevant facts that have been represented to us.

     We have assumed, with your consent, that (i) the Merger will be effected in accordance with the Merger Agreement, (ii) the statements of fact concerning the Merger set forth in the Merger Agreement and the Registration Statement are true, correct and complete and will remain true, correct and complete at all times up to and including the Effective Time, (iii) the representations made by ARRIS, Merger Sub, and C-COR in their respective Certificates are true, correct and complete and will remain true, correct and complete at all times up to and including the Effective Time, and (iv) any representations made in the Merger Agreement or the Certificates “to the knowledge of,” or based on the belief of ARRIS, Merger Sub, and C-COR or similarly qualified are true, correct and complete and will remain true, correct and complete at all times up to and including the Effective Time, in each case without such qualification. We have not, however, undertaken any independent investigation of any factual matter set forth in any of the foregoing.

ARRIS Group, Inc.
Ocotber 12, 2007
Page 2

     We hereby confirm to you that, in our opinion, the discussion in the section of the Proxy Statement/Prospectus captioned “MATERIAL FEDERAL INCOME TAX CONSEQUENCES OF THE MERGER,” to the extent it states matters of law or legal conclusions, correctly sets forth the material U.S. federal income tax consequences of the Merger to C-COR shareholders.

     Except as set forth above, we express no opinion as to the accuracy of any statements of law relating to the Merger or as to any other legal matters.

     The opinion expressed herein is based upon our analysis of the Internal Revenue Code of 1986, as amended, the U.S. Treasury regulations promulgated thereunder, administrative positions of the Internal Revenue Service, and judicial decisions as of the date hereof and represents our best legal judgment as to the matters addressed herein. Our opinion, however, is not binding on the Internal Revenue Service or the courts. Accordingly, no complete assurance can be given that the opinion expressed herein, if contested, would be sustained by a court. Moreover, the authorities upon which our opinion is based are subject to change, possibly on a retroactive basis, and any such change could affect the opinion rendered herein.

     We are furnishing this opinion to you solely in connection with the filing of the Registration Statement. We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the use of our name in the Proxy Statement/Prospectus which is a part thereof under the captions “LEGAL MATTERS” and “MATERIAL FEDERAL INCOME TAX CONSEQUENCES OF THE MERGER.” In giving this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended, and the rules and regulations thereunder.

Very truly yours,


/s/ Troutman Sanders LLP