EXHIBIT 5

                                                                December 4, 2001

Robert Barcelon, President
Commercial Evaluations, Inc.
2320 Paseo Del Prado, Building B, Suite 1
Las Vegas, Nevada 89129

Re:      Commercial Evaluations, Inc. (the "Company")

Dear Mr. Barcelon:

     Pursuant to your request, I have provided this opinion letter to be used in
connection with the Company's application to register securities for sale via a
public stock offering pursuant to Regulation S-B of the Securities Act of 1933,
as amended. The Company has supplied me with the following Company documents
with regards to this review: (1) Articles of Incorporation; (2) Bylaws of the
Company; (3) Complete minute book of the Company; (4) The Company's Form SB-2
Registration Statement; (5) The Company's Prospectus; (6) Public Subscription
Agreement; and (7) Audited Financial Statements.

     Based upon my review of the above-mentioned documents, provided to me by
the Company, it is my opinion that any common shares sold in this public
offering will be legally issued, fully paid and non-assessable upon issuance.

     This legal opinion should in no way be construed to recommend the purchase
of any securities and does not in any way form on opinion as to the merits of
the offering. It is with my express permission that the Company may utilize this
opinion letter in regards to any public registration filing, both state and
federal. It is also with my express permission that the Company may name the
undersigned as counsel in any public registration filing, both state and
federal.

                                            Sincerely,

                                            /s/

                                            Thomas C. Cook, Esq.