I haven't seen the 10g documentation yet, but if the upgrade is like previous versions, it should be pretty easy if you use the Database Upgrade Assistant (DBUA). The DBUA handles all of the details for you. Without having seen the docs yet, I would be prepared to upgrade to 9.2.0 as an interim step before proceeding to 10g. However, it may be possible to upgrade from 8.1.7 to 10g directly. I'll know more once 10g hits the market officially.
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