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                  [MALSON, EDELMAN, BORMAN & BRAND LETTERHEAD]


                                                                    EXHIBIT 5



                                 April 30, 1999




Lakes Gaming, Inc.
130 Cheshire Lane
Minnetonka, Minnesota 55305


         Re:  Registration Statement on Form S-8


Ladies and Gentlemen:

         We have acted on behalf of Lakes Gaming, Inc. (the "Company") in
connection with a Registration Statement on Form S-8 (the "Registration
Statement") filed by the Company with the Securities and Exchange Commission
relating to an aggregate of 941,735 shares of Common Stock, $.01 par value, to
be issued by the Company (the "Shares"), pursuant to the terms of the Company's
Assumed Stock Option Plan (the "Plan"). Upon examination of such
corporate documents and records as we have deemed necessary or advisable for the
purposes hereof, it is our opinion that:

         1. The Company is a validly existing corporation in good standing under
         the laws of the State of Minnesota.

         2. The Shares, when issued and paid for as contemplated by the Plan,
         and when delivered against payment thereof in the manner contemplated
         by the Plan, will be validly issued, fully paid and non-assessable.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement.


                                             Very truly yours,

                                             Maslon Edelman Borman & Brand, LLP