EXHIBIT 5

                                 August 27, 2002

Robert Barcelon, President
Commercial Evaluations, Inc.
2320 Paseo Del Prado, Building B, Suite 205
Las Vegas, Nevada 89102

Re:      Commercial Evaluations, Inc. (the "Company")
         Securities and Exchange Commission File Number 333-75272

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 400,000 shares of
its common stock 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 the laws of the State of Nevada and 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,



                                            -----------------------------------
                                            Thomas C. Cook, Esq.