Exhibit 5.1
[Letterhead of The Xxxx Law Group]
July 26, 2004
ACS Holdings, Inc.
0000 Xxxxxxxxx Xxxxx
Xxxxxxx, Xxxxxxx 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 100,000,000 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, July 12, 2004 and July 26, 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, June 1, 2004, July 12, 2004 and July 26, 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
