Securities Commissioner                                     August 21, 1998
Securities and Exchange Commission
450 5th Street NW
Washington, DC. 20549





Dear Commissioner,

     We have acted as counsel to American Card Technology, Incorporated, a
Delaware corporation, in connection with the preparation of a Regulation SB
Offering Statement (the "Offering Statement" on Form SB-2, to be filed with the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933. The Offering Statement relates to the sale of 648,900 shares of Common
Stock, with par value of $.001 (the "Common Stock") as more particularly
described in the Offering Statement.

     In connection therewith, we have examined (i) the Articles of Incorporation
and the By-Laws of American Card Technology, Incorporated; (ii) records of the
corporate proceedings of American Card Technology, Incorporated with respect to
the issuance of shares of Common Stock by American Card Technology,
Incorporated; (iii) the Offering Statement; and (iv) and such other documents as
we have deemed necessary for the expression of the opinions contained herein.

     In making the foregoing examinations, we have assumed the genuineness of
all signatures and the authenticity of all documents submitted to us as
originals, and the conformity to original documents of all documents submitted
to us as certified or photo-static copies. As to questions of fact material to
this opinion, where such facts have not been independently established by us,
and as to the content and form of Articles of Incorporation, By-Laws, minutes
and resolutions and other documents or writings, we have relied to the extent we
deemed reasonably appropriate, upon representations of corporate officers or
certificates of governmental officials. We express no opinion as to compliance
with applicable state anti-fraud statutes, rules or regulations concerning the
issuance of securities.






Opinion of Consul
Page 2 of 2


     Based upon and subject to the foregoing and having due regard for such
legal considerations that we deem relevant, we are of the opinion (i) that the
Common Stock has been duly authorized for issuance and (ii) that upon payment
for, and issuance of, the Common Stock in accordance with the terms of the
Offering Statement, the Common stock will be validly issued and will be fully
paid and non-assessable.







Sincerely,

     /s/ R. John Bartz

BARTZ & BARTZ, P.A.


R. John Bartz
Attorney at Law