EXHIBIT 5.1

                                January 18, 2002



Acres Gaming Incorporated
7115 Amigo, Suite 150
Las Vegas, Nevada 89119

        RE: 3,033,639 SHARES OF COMMON STOCK, $.01 PAR VALUE PER SHARE, OF ACRES
            GAMING INCORPORATED

Ladies and Gentlemen:

        We have acted as counsel to Acres Gaming Incorporated (the "Company") in
connection with the preparation of a Registration Statement on Form S-3 (the
"Registration Statement"), under the Securities Act of 1933, as amended (the
"Act"), with respect to 3,033,639 shares of the Company's Common Stock, $.01 par
value per share (the "Shares"), that are issuable upon the conversion of the
Company's 6% Convertible Subordinated Debentures (the "Debentures") or upon the
exercise of certain warrants (the "Warrants") pursuant to the respective terms
thereof. We have examined the Registration Statement and such documents and
records of the Company as we have deemed necessary for the purpose of this
opinion.

        Based upon and subject to the foregoing, we are of the opinion that the
Shares have been duly authorized and, when and if issued and delivered upon
conversion of the Debentures or exercise of the Warrants, such Shares will be
validly issued, fully paid and nonassessable.

        We consent to the filing of this opinion as an exhibit to the
Registration Statement. In giving such consent, we do not admit that we are in
the category of persons whose consent is required under Section 7 of the Act.

                                            Very truly yours,



                                            PERKINS COIE LLP