EXHIBIT 5.1

                                  May 9, 2003

Universal Tanning Ventures, Inc.
600 East Altamonte Drive, Unit 1050
Altamonte Springs, Florida 32701

Ladies and Gentlemen:

     In connection with the Registration Statement on Form SB-2 and the
amendments thereto (collectively the "Registration Statement") filed by
Universal Tanning Ventures, Inc., a Delaware corporation (the "Company"), under
the Securities Act of 1933, as amended (the "Act"), relating to the public
offering by the Company of up to 1,000,000 shares (the "Shares") of its common
stock, par value $0.0001 (the "Common Stock"), we, as legal counsel for the
Company, have examined such corporate records, other documents and questions of
law as we have considered necessary or appropriate for the purpose of this
opinion. Our opinion set forth below is limited to Delaware law.

     We assume that appropriate action will be taken, prior to the offer and
sale of the Shares, to register and qualify the Shares for sale under all
applicable state securities or "blue sky" laws and the laws of any foreign
jurisdictions.

     In the examination of the foregoing documents, we have assumed the
genuineness of all signatures and the authenticity of all documents submitted to
us as originals, the conformity to original documents of all documents submitted
to us as certified or photostatic copies, and the authenticity of the originals
of such latter documents.

     Based on the foregoing, we advise you that, in our opinion, the Shares have
been duly and validly authorized and, when issued and sold in the manner
contemplated by the Registration Statement, and upon receipt by the Company of
payment therefore as provided therein, the shares will be legally issued, fully
paid and non-assessable.

     We hereby consent to the filing of this opinion with the Securities and
Exchange Commission as an exhibit to the Registration Statement and to the
reference to our firm under the heading "Legal Matters" therein. This consent is
not to be construed as an admission that we are a party whose consent is
required to be filed with the Registration Statement under the provisions of the
Act or the rules and regulations of the Securities and Exchange Commission
promulgated thereunder.

     The opinion expressed herein is solely for your benefit, and may be relied
upon only by you.

                                              Sincerely,


                                              /s/ GREENBERG TRAURIG, P.A.