September 22, 1999

Board of Directors
Multi-Link Telecommunications, Inc.
4704 Harlan Street, Suite 420
Denver, Colorado  80212

Re:  Form S-8 Registration Statement
     Opinion of Counsel

Gentlemen:

     You have requested our opinion as to certain matters that relate to 392,885
shares of the $0.01  par value  common  stock  ("Common  Stock")  of  Multi-Link
Telecommunications,  Inc.  ("Company")  that may be issued upon the  exercise of
options that have been granted,  and that may in the future be granted  pursuant
to the Company's Amended Stock Option Plan ("Plan"), that may be issued pursuant
to grants under the Plan and that have been granted to Steve Inman,  Doug Cohen,
Mary Hugo,  Tanya Riddle,  Don Klick,  Keith R. Holder,  R. Brad Stillahn Samuel
Soudani, Janice Wilkins and Mari Christie.

     We have reviewed the Restated Articles of Incorporation of the Company, the
Plan, the option  certificates  for the options  granted under the Plan and such
other documents that we considered necessary in order to render this opinion. As
a result of our  review,  we are of the  opinion  that,  assuming  the shares of
Common Stock are paid for as described in the Plan and the option  certificates,
when issued,  the shares of Common Stock will be validly issued,  fully paid and
nonassessable.

     This  opinion  is  limited  to  applicability  of  the  Colorado   Business
Corporation  Act and the  Colorado  common law to the  issuance of the shares of
Common  Stock.  This  opinion  does not  cover or is in any way  related  to the
applicability  of, or compliance by the Company with,  any other law,  including
any federal or state  securities  laws,  any other state common law or any other
federal law.

     We consent to you describing  this firm as having issued the opinion in the
prospectus that is a part of the registration statement referenced above.

                                        Very truly yours,


                                        /s/ SMITH MCCULLOUGH, P.C.
                                        SMITH MCCULLOUGH, P.C.