EXHIBIT 5.1

                                                       [PERKINS COIE LETTERHEAD]


                                January 17, 2003



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

RE:   REGISTRATION STATEMENT ON FORM S-8

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-8 (the
"Registration Statement"), under the Securities Act of 1933, as amended (the
"Act"), that you are filing with the Securities and Exchange Commission with
respect to up to 1,289,800 shares of the Company's Common Stock, $.01 par value
per share (the "Shares"), that may be issued under the Acres Gaming Incorporated
2002 Stock Incentive Plan (the "Plan"). 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.

      We are of the opinion that any of the Shares that may be issued and sold
by the Company pursuant to the Plan have been duly authorized and, upon due
execution by the Company of certificates representing such Shares, the
registration by its registrar of such Shares and the sale thereof, and the
receipt of consideration therefor, by the Company in accordance with the terms
of the Plan, 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,



                                            /s/ PERKINS COIE LLP