EXHIBIT 5.1

                 [LETTERHEAD OF KELLY LYTTON MINTZ & VANN LLP]



                               September 1, 1999



BioLase Technology, Inc.
981 Calle Amanecer
San Clemente, California 92673

     Re:  BioLase Technology, Inc. - Registration Statement on Form S-3
          -------------------------------------------------------------

Ladies and Gentlemen:

     We have acted as counsel to BioLase Technology, Inc., a Delaware
corporation (the "Company"), in connection with the issuance and sale or
proposed issuance and sale by the Company of an aggregate of 4,020,200 shares of
its Common Stock, par value $.001 per share (the "Shares"), which have been
registered for resale pursuant to the Company's Registration Statement on Form
S-3 filed with the Securities and Exchange Commission under the Securities Act
of 1933, as amended (the "Act").

     For purposes of rendering this opinion, we have made such legal and factual
inquiries and examinations, including reviews of the Company's charter documents
and the corporate proceedings taken by the Company in connection with the
issuance and sale of the Shares, as we deem necessary or appropriate.  Based on
such inquiries and examinations and relying thereon, we are of the opinion that:

     1.  The Shares have been duly authorized.

     2.  Those Shares which are presently outstanding have been legally issued
and are fully paid and non-assessable.

     3.  Those Shares which are not presently outstanding, when and if issued in
the manner contemplated in said Registration Statement and in the instruments
pursuant to which such Shares are issuable and upon payment therefor in
accordance with the terms of such instruments, will be legally issued, fully
paid and non-assessable.

     In rendering this opinion, we have assumed the authenticity, accuracy and
completeness of all documents submitted to us as originals, the conformity to
originals of all documents submitted to us as copies thereof, and the accuracy
of representations made by officers of the Company in certificates delivered to
us regarding factual matters.


     We are licensed to practice law only in the State of California and, except
as specifically set forth in this paragraph, render no opinion herein as to
matters involving the laws of any jurisdiction other than the State of
California and the United States of America.  We are generally familiar with the
General Corporation Law of the State of Delaware, and this opinion extends to
matters governed by the General Corporation Law of the State of Delaware.  This
opinion is limited to the laws presently in effect and to the facts as they
presently exist.  We assume no obligation to revise or supplement this opinion
should the present laws of the State of California or the United States of
America or the General Corporation Law of the State of Delaware be changed by
legislative action, judicial decision or otherwise.  This opinion is rendered as
of the date hereof, and we express no opinion, and expressly disclaim any
undertaking or obligation to update this opinion, in respect of changes of
circumstances, events or laws subsequent to this date.

     We consent to this opinion being filed as an exhibit to said Registration
Statement and to the reference to this firm under the caption "Legal Matters" in
the prospectus constituting a part of said Registration Statement.  In giving
this consent, we do not admit that we are in the category of persons whose
consent is required under Section 7 of the Act or the rules and regulations of
the Commission thereunder.

                                    Very truly yours,

                                    /s/ Kelly Lytton Mintz & Vann LLP
                                    -----------------------------------
                                    Kelly Lytton Mintz & Vann LLP