EXHIBIT 5.1

                 [BREWER & PRITCHARD LETTERHEAD APPEARS HERE]

                               February 19, 1999


Eagle Wireless International, Inc.
910 Gemini
Houston, Texas 77058

      Re:   Eagle Wireless International, Inc.
            Registration Statement on Form S-8

Gentlemen:

      We have represented Eagle Wireless International, Inc., a Texas
corporation ("Company"), in connection with the preparation of a registration
statement filed with the Securities and Exchange Commission on Form S-8
("Registration Statement") relating to the proposed issuance of up to 400,000
shares ("Shares") of the Company's common stock, par value $.001 per share
("Common Stock") pursuant to the terms of the 1996 Incentive Stock Option Plan
("Plan"). In this connection, we have examined originals or copies identified to
our satisfaction of such documents, corporate and other records, certificates,
and other papers as we deemed necessary to examine for purposes of this opinion,
including but not limited to the Plan, the Articles of Incorporation of the
Company, the Bylaws of the Company, and resolutions of the Board of Directors of
the Company.

      We are of the opinion that the Shares will be, when issued pursuant to the
Plan, legally issued, fully paid and nonassessable.

      We hereby consent to the filing of this Opinion as an Exhibit to the
Registration Statement.

                                          Very truly yours,
 
                                          BREWER & PRITCHARD, P.C.

                                          //s// Brewer & Pritchard, P.C.