August 21, 2026

Synaptics Incorporated

1109 McKay Drive

San Jose, California 95131

Ladies and Gentlemen:

We have acted as U.S. federal income tax counsel to Synaptics Incorporated, a Delaware corporation (the “Company”), in connection with the transactions contemplated by the Agreement and Plan of Reorganization, dated as of June 25, 2026 (the “Agreement”), by and among the Company; ON Semiconductor Corporation, a Delaware corporation (“Parent”) and Sonic Acquisition Corp., a Delaware corporation and direct, wholly owned subsidiary of Parent (“Merger Sub”).  Pursuant to the Agreement, Merger Sub will be merged with and into Company (the “Merger”), whereupon the separate existence of Merger Sub shall cease, and Company shall be the surviving corporation (the “Surviving Corporation”) and a wholly owned subsidiary of Parent. For purposes of this opinion, capitalized terms used and not otherwise defined herein shall have the meaning ascribed to them in the Agreement and references herein to the Agreement shall include all exhibits and schedules thereto.  This opinion is being delivered in connection with the registration statement of Parent on Form S-4 filed on the date hereof with the Securities and Exchange Commission, including the joint proxy statement/prospectus (collectively, the “Registration Statement”), as required by Section 4.4 of the Agreement.

We have examined (i) the Agreement, (ii) the Registration Statement and (iii) the representation letters of the Company and Parent (together with Merger Sub) delivered to us for purposes of this opinion pursuant to Section 4.10(c) of the Agreement (the “Representation Letters”).  In addition, we have examined, and relied as to matters of fact upon, originals or copies, certified or otherwise identified to our satisfaction, of such corporate records, agreements, documents and other instruments and made such other inquiries as we have deemed necessary or appropriate to enable us to render the opinion set forth below.  In such examination, we have assumed the genuineness of all signatures, the legal capacity of natural persons, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as duplicates or certified or conformed copies, and the authenticity of the originals of such latter documents.  We have not, however, undertaken any independent investigation of any factual matter set forth in any of the foregoing.

In rendering this opinion, we have assumed, with your permission, that (i) the Merger will be effected in accordance with the Agreement, (ii) the factual statements concerning the Merger set forth in the Agreement and the Registration Statement are true, complete and correct and will remain true, complete and correct at all times up to and including the Effective Time, (iii) the representations made by the Company and by Parent (together with Merger Sub) in their respective Representation Letters and in the Agreement are true, complete and correct and will remain true, complete and correct at all times up to and including the Effective Time, (iv) any representations or statements made in the Agreement or the Representation Letters “to the knowledge of”, or based on the belief of the Company, Parent or Merger Sub, or similarly qualified, are true, complete and correct and will remain true, complete and correct at all times up to and including the Effective Time, in each case without such qualification and (v) all applicable reporting requirements have been or will be satisfied.  We have also assumed that the parties have satisfied and complied with and, if applicable, will continue to satisfy and comply with, the relevant covenants and obligations contained in the Agreement and the various other documents related thereto.  If any of the above described assumptions are untrue for any reason, the conclusions stated in our opinion might be adversely affected.

Based upon the foregoing, and subject to the limitations, qualifications and assumptions stated herein and in the Registration Statement, in our opinion the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended (the “Code”).  In addition, we are of the opinion that the discussion set forth in the Registration Statement under the heading “U.S. Federal Income Tax Consequences of the Merger”, insofar as such discussion purports to constitute summaries of matters of U.S. federal income tax law or legal conclusions with respect thereto and insofar as such discussion relates to the U.S. federal income tax consequences of the Merger to U.S. holders (as defined in the Registration Statement) of Company Common Stock, is accurate in all material respects.

We express our opinion herein only as to those matters specifically set forth above and no opinion should be inferred as to the tax consequences of the Merger under any state, local or foreign laws, or with respect to other areas of U.S. federal taxation.  We do not express any opinion herein concerning any law other than the federal law of the United States.

Our opinion is based on current statutory, regulatory and judicial authority, any of which might be changed at any time with retroactive effect.  Our opinion is not binding upon the Internal Revenue Service or the courts, and there is no assurance that the Internal Revenue Service will not assert a contrary position. Furthermore, no assurance can be given that future legislative, judicial or administrative changes, on either a prospective or retroactive basis, would not adversely affect the accuracy of the conclusions stated herein. Nevertheless, we disclaim any undertaking to advise you of any subsequent changes of the matters stated, represented or assumed herein or any subsequent changes in applicable law, regulations or interpretations thereof.

No opinion is expressed as to any transaction other than the Merger as described in the Agreement, the Registration Statement and the Representation Letters, or to any transaction whatsoever, including the Merger, if, to the extent relevant to our opinion, either all the transactions described in the Agreement are not consummated in accordance with the terms of the Agreement and without waiver or breach of any provisions thereof or all of the factual statements, representations, warranties and assumptions upon which we have relied are not true and accurate at all relevant times.

We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference to our firm name therein under the captions “U.S. Federal Income Tax Consequences of the Merger” and “Legal Matters.” In giving this consent, we do not admit that we are within 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 promulgated thereunder.

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