[Stepp Law Group Letterhead]





September 5, 2003

Universal Domains Incorporated
502-828 Howe Street
Vancouver, British Columbia V6Z 2X2

Re:   Registration Statement on Form S-8

Attention:   Alan Brown

Dear Mr. Brown:

We have been  retained by Universal  Domains  Incorporated,  a Canadian  Federal
corporation  (the  "Company"),  as  special  counsel  to  review a  Registration
Statement on Form S-8 which the Company  intends to file with the Securities and
Exchange  Commission (the  "Commission"),  in connection  with the  registration
pursuant to the  Securities  Act of 1933, as amended,  of  24,800,000  shares of
common  stock to be issued by the  Company  (the  "Shares")  (the  "Registration
Statement"). The Shares will be issued to John Formicola, Tom Reid, John Boldis,
Duncan McKechnie,  Mike Edwards,  Fred Guarnieri,  Suraj Jaswal,  Dorothy Brown,
Lisa Lehner,  David Flynn,  and Victoria Chen,  consultants to the Company.  The
Shares will be issued to those persons  pursuant to the provisions of Consulting
Services Agreements entered into among the Company and those persons,  copies of
which are attached as exhibits to the Registration Statement (the "Agreements").

In furnishing the opinion  specified in this letter,  we examined such documents
and reviewed such  questions of law as we considered  necessary or  appropriate.
Based upon the  foregoing,  and relying  solely  thereon,  and assuming that the
Shares  will be  issued  on the  terms  and  subject  to the  conditions  of the
Registration  Statement and the  Agreements,  it is our opinion that the Shares,
when issued,  subject to the  effectiveness  of the  Registration  Statement and
compliance  with  applicable  securities  and  other  laws of any state or other
jurisdiction  in  which  the  Shares  will be  offered  and  sold,  will be duly
authorized,  validly  issued  and  non-assessable.  We  express no opinion as to
compliance with the securities laws or other laws in any particular jurisdiction
in which the Shares are proposed to be sold and as to the effect,  if any, which
non-compliance with such laws might have regarding the transactions contemplated
by this letter.






Universal Domains Incorporated
September 5, 2003
Page 2



We  consent  to the  use of  this  opinion  as an  exhibit  to the  Registration
Statement.  In giving this  consent,  we do not hereby  admit that we are in the
category of persons whose  consent is required  pursuant to Section 7 of the Act
or the rules and regulations of the Commission pursuant thereto.

This opinion (i) is addressed  solely to you, (ii) may not be relied upon by any
other party,  (iii) relates only to matters of United States federal  securities
law and nothing in this opinion shall be deemed to imply any opinion  related to
the laws of any  other  jurisdiction,  and (iv) may not be  relied  upon for any
other purpose whatsoever. Nothing in this letter shall be deemed to relate to or
constitute an opinion  concerning any matters not specifically set forth in this
letter.

The Company is hereby  advised,  urged and  encouraged  to retain  qualified and
competent securities counsel in each particular jurisdiction in which the Shares
may be offered and sold regarding  compliance  with the securities  laws of such
jurisdiction.

This opinion is as of the date of this letter.

Sincerely,

STEPP LAW GROUP



/s/ Thomas E. Stepp, Jr.

By: Thomas E. Stepp, Jr.
TES:mej