EXHIBIT 5.1
[Letterhead of The Xxxx Law Group]
July 12, 2004
ACS Holdings, Inc.
0000 Xxxxxxxxx Xxxxx
Xxxxxxx, XX 00000
Ladies and Gentlemen:
In connection with the registration on Form S-8 under the Securities Act
of 1933, as amended, of an aggregate of 65,000,000 shares of common stock (the
"Shares") to be issued pursuant to a Consulting Services Agreement dated
February 12, 2004, by and between ACS Holdings, Inc., a Nevada corporation
("ACS") and Xxxxxxxxxxx International Investments Ltd., Inc., as amended on
April 22, 2004, June 1, 2004 and July 12, 2004 (the "Xxxxxxxxxxx Agreement"),
and a Consulting Services Agreement dated February 12, 2004, by and between ACS
and The Xxxx Law Group, PLLC, as amended on April 22, 2004, May 19, 2004 and
June 1, 2004 and June 12, 2004 (the "OLG Agreement"), we have examined such
documents and have reviewed such questions of law as we have considered
necessary and appropriate for the purposes of this opinion and, based thereon,
we advise you that, in our opinion, when the Shares have been issued and sold
pursuant to the applicable provisions of the Xxxxxxxxxxx Agreement and the OLG
Agreement and in accordance the Form S-8, the Shares will be validly issued,
fully paid and nonassessable shares of the Company's common stock.
We hereby consent to the filing of this opinion as an exhibit to the
above-described registration statement.
Very truly yours,
THE XXXX LAW GROUP, PLLC
/s/ The Xxxx Law Group
