Exhibit 5.1



               Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
                              One Financial Center
                           Boston, Massachusetts 02111


701 Pennsylvania Avenue, N.W.                           Telephone: 617/542-6000
Washington, D.C. 20004                                  Fax: 617/542-2241
Telephone: 202/434-7300                                 www.mintz.com
Fax: 202/434-7400



                                 March 22, 2002

Ibis Technology Corporation
32 Cherry Hill Drive
Danvers, MA 01923

Ladies and Gentlemen:

     This opinion is furnished to you in connection with a Prospectus Supplement
to an effective Registration Statement on Form S-3, Registration No. 333-82497
(collectively, the "Registration Statement") being filed by Ibis Technology
Corporation, a Massachusetts corporation (the "Company"), with the Securities
and Exchange Commission (the "Commission") under the Securities Act of 1933, as
amended (the "Securities Act"), with respect to 1,000,000 shares (the "Shares")
of its common stock, $.008 par value per share (the "Common Stock") (including
100,000 Shares subject to the underwriter's over-allotment option). All of the
Shares are to be sold to SoundView Technology Corporation ("SoundView") pursuant
to an Underwriting Agreement between the Company and SoundView (the
"Underwriting Agreement"), which Underwriting Agreement will be filed as an
exhibit to a Current Report on Form 8-K.

     In connection with this opinion, we have examined the Company's Restated
Articles of Organization, as amended, and Restated Bylaws, both as currently in
effect; the minutes, as provided to us by the Company, of all pertinent meetings
of directors of the Company relating to the Registration Statement and the
transactions contemplated thereby; the Underwriting Agreement; such other
records of the corporate proceedings of the Company and certificates of the
Company's officers and such other documents as we deemed relevant; and the
Registration Statement and the exhibits thereto filed with the Commission.

     In our examination, we have assumed the genuineness of all signatures, the
legal capacity of natural persons, the authenticity of all documents submitted
to us as originals, the conformity to original documents of all documents
submitted to us as certified, photostatic or facsimile copies and the
authenticity of the originals of such copies.

     Based upon the foregoing, and subject to the limitations set forth below,
we are of the opinion that the Shares, when issued by the Company and delivered
by the Company against payment therefor as contemplated by the Underwriting
Agreement, will be duly and validly issued, fully paid and non-assessable shares
of the Common Stock.





Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.


March 22, 2002
Page 2




     Our opinion is limited to the federal law of the United States of America
and the laws of the Commonwealth of Massachusetts, and we express no opinion
with respect to the laws of any other jurisdiction. No opinion is expressed
herein with respect to the qualification of the Shares under the securities or
blue sky laws of any state or any foreign jurisdiction. To the extent that any
applicable document is stated to be governed by the laws of another
jurisdiction, we have assumed for purposes of this opinion that the laws of such
jurisdiction are identical to the laws of the Commonwealth of Massachusetts.

     Please note that we are opining only as to the matters expressly set forth
herein, and no opinion should be inferred as to any other matters. This opinion
is rendered as of the date hereof and is based upon currently existing statutes,
rules, regulations and judicial decisions, and we disclaim any obligation to
advise you of any change in any of these sources of law or subsequent legal or
factual developments which might affect any matters or opinions set forth
herein.

     We hereby consent to the filing of this opinion with the Commission as an
exhibit to the Registration Statement in accordance with the requirements of
Item 601(b)(5) of Regulation S-K under the Securities Act and to the use of this
Firm's name therein and in the Prospectus Supplement under the caption "Legal
Matters." In giving such consent, we do not hereby admit that we are in the
category of persons whose consent is required under Section 7 of the Securities
Act or the rules and regulations of the Commission.

                                         Very truly yours,

                                         /s/ Mintz, Levin, Cohn, Ferris,
                                         Glovsky and Popeo, P.C.

                                         Mintz, Levin, Cohn, Ferris,
                                         Glovsky and Popeo, P.C.