EXHIBIT 5.1

July 31, 2003

GelStat Corporation
Southpoint Office Center, Suite 1040
1650 West 82nd Street
Bloomington, Minnesota  55431

Re:  1,200,000  Shares of Common  Stock,  par value $.01 per share,  and related
     rights to purchase Common Stock issued pursuant to the GelStat  Corporation
     2003 Incentive Plan (the "Plan")

Ladies and Gentlemen:

We have served as legal counsel to GelStat Corporation,  a Minnesota corporation
(the "Company") in connection with the proposed issuance of the Common Stock and
related  rights to purchase  Common Stock referred to above  (collectively,  the
"Shares"),  pursuant to the Plan.  The Shares are the  subject of the  Company's
Registration  Statement  on Form S-8 (the  "Registration  Statement")  under the
Securities  Act of 1933,  as  amended  (the  "Securities  Act"),  to which  this
opinion, with our consent, is attached as an exhibit.

We have examined all records,  instruments,  and documents  which we have deemed
necessary  to  examine  for  the  purposes  of  this   opinion,   including  the
registration statements on Form S-8, as amended, relating to the predecessors to
the Plan previously filed by the Company pursuant to the Securities Act.

Based upon the foregoing and upon our general  familiarity  with the Company and
its properties and affairs, we are of the opinion that:

1)   The Company is a duly organized and validly existing  corporation under the
     laws of the State of Minnesota and is legally  qualified and  authorized to
     operate and conduct business in the State of Minnesota.

2)   When, as and if the Registration  Statement becomes  effective  pursuant to
     the  provisions of the  Securities Act and the Shares have been duly issued
     and delivered,  and the consideration for the Shares has been duly received
     by the  Company,  all in  the  manner  contemplated  by  said  Registration
     Statement,  the Shares will be legally issued, fully paid and nonassessable
     shares of stock and rights to purchase shares of stock of the Company.

We hereby  consent to the  incorporation  of this opinion into the  Registration
Statement.

Respectfully submitted,

MOSS & BARNETT
A Professional Association


Janna R. Severance