Exhibit 5.1

                         [Letterhead of Loeb & Loeb LLP]


                                                June 10, 2004


Kubla Khan, Inc.
57-71 #High-Tech Industrial Park NanShan,
District Shenzhen, P.R. China 51805

      Re:   Registration Statement on Form S-8

Ladies and Gentlemen:

      We have served as your counsel in connection with the preparation of your
Registration Statement on Form S-8 to be filed with the Securities and Exchange
Commission in connection with the registration under the Securities Act of 1933,
as amended, of 5,070,000 shares of your common stock, $0.001 par value (the
"Common Stock"), reserved for issuance pursuant to the Kubla Khan, Inc. 2004
Equity Incentive Plan (the "Plan"). We have examined such corporate records,
documents and matters of law as we have considered appropriate for the purposes
of this opinion.

      Based upon such examination and our participation in the preparation of
the Registration Statement, it is our opinion that the Common Stock, when issued
in the manner described in the Plan, will be validly issued, fully paid and
non-assessable.

      We consent to the reference made to our firm in the Registration Statement
and to the filing of this opinion as an exhibit to the Registration Statement.


                                          Sincerely,


                                          /s/ Loeb & Loeb LLP
                                          --------------------------------------
                                          LOEB & LOEB LLP