Exhibit 5.1










                               Leonard E. Neilson
                           A PROFESSIONAL CORPORATION

LEONARD  E.  NEILSON                   8160  SOUTH  HIGHLAND  DRIVE,  SUITE  104
ATTORNEY  AT  LAW                                  SANDY,  UTAH  84093
                                                     TELEPHONE:  (801)  733-0800
                                                           FAX:  (801)  733-0808
                                                    E-MAIL:  LNEILSONLAW@AOL.COM


                                  May 17, 2007



Nine Mile Software, Inc.
1245 East Brickyard Road
Suite 590
Salt Lake City, Utah 84106

         Re:      Nine Mile Software, Inc.
                  Registration Statement on Form SB-2

Ladies and Gentlemen:

         I have acted as special  counsel to Nine Mile Software,  Inc., a Nevada
corporation (the "Corporation"),  in connection with its registration  statement
on Form SB-2 filed with the Securities and Exchange  Commission  pursuant to the
Securities  Act of 1933, as amended (the  "Securities  Act").  The  registration
statement relates to the proposed public offering of up to 714,290 shares of the
Corporation's common stock, par value $0.001 per share (the "Common Stock").

         This  opinion  is  being  furnished  to you  in  accordance  with  Item
601(b)(5) of Regulation S-B, promulgated under the Securities Act, for filing as
Exhibit 5.1 to the above referenced registration statement.

         In connection with the  registration  statement and, for the purpose of
rendering  this  opinion,   I  have  examined  the  Corporation's   Articles  of
Incorporation, Bylaws and pertinent minutes and resolutions of the Corporation's
Board of Directors.  I have also examined  such other  documents,  certificates,
instruments and corporate records, and such statutes, decisions and questions of
law as I have deemed necessary or appropriate for the purpose of this opinion.

         I have been  furnished  with  originals or copies of such  corporate or
other records of the Corporation.  In addition, I have made such other legal and
factual examinations and inquiries as I have considered necessary as a basis for
the opinion expressed  herein. In my examination of the Corporation's  corporate
records, I have presumed, without independent investigation, the authenticity of
all documents submitted to me as originals, the conformity to original documents
of all  documents  submitted to me as copies  thereof,  the  genuineness  of all
signatures  and the  veracity,  accuracy  and  completeness  of all records made
available to me by the Corporation.

         As to the  question of facts  material to this opinion  letter,  I have
relied  upon  the   representations   and   warranties,   certificates   of  and
conversations and correspondences with representatives of the Corporation.

         My opinion is expressly limited to those matters set forth herein and I
make no opinion,  expressed or implied,  as to any other matters relating to the
Corporation or its securities.



Nine Mile Software, Inc.
May __, 2007
Page 2

         Based upon and subject to the  foregoing,  I am of the opinion that the
Common  Stock  being  offered  to the public by the  Corporation,  when sold and
issued in the manner  described in the  registration  statement (as amended from
time to time), will be validly issued, fully paid and non-assessable.






         I hereby  consent  to the  filing of this  opinion as an Exhibit to the
registration  statement  and to  the  reference  to my  name  in the  Prospectus
constituting  a part thereof under the caption  "Legal  Matters." In giving this
consent,  I do not admit that I am within the category of persons  whose consent
is required under the Securities Act, including Section 7 thereof,  or rules and
regulations promulgated thereunder.

         This opinion is furnished to you in  connection  with the filing of the
registration  statement and is not to be used,  circulated,  quoted or otherwise
relied upon for any other purpose.

                                  Yours truly,



                                  LEONARD E. NEILSON, ATTORNEY AT LAW, P.C.