EXHIBIT 5.1

                                 STEVENS AND LEE
                             LAWYERS AND CONSULTANTS
                           620 FREEDOM BUSINESS CENTER
                                    SUITE 200
                                  PO BOX 62330
                            KING OF PRUSSIA, PA 19406

                                                              October 12, 2004

VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

      Re: Kingdom Ventures, Inc.

Ladies and Gentlemen:

      We  refer to the  registration  statement  on Form S-8 (the  "Registration
Statement")  under the Securities Act of 1933, as amended (the "Act"),  filed by
Kingdom  Ventures,  Inc.,  a  Nevada  corporation  (the  "Company"),   with  the
Securities and Exchange Commission.

      We have examined the  originals,  photocopies,  certified  copies or other
evidence of such records of the Company, certificates of officers of the Company
and  public  officials,  and other  documents  as we have  deemed  relevant  and
necessary as a basis for the opinion hereinafter expressed. In such examination,
we have assumed the  genuineness  of all  signatures,  the  authenticity  of all
documents   submitted  to  us  as  certified   copies  or  photocopies  and  the
authenticity of the originals of such latter documents.

      Based on our examination  mentioned  above, we are of the opinion that the
securities being  registered to be sold pursuant to the  Registration  Statement
are duly  authorized  and will be,  when  sold in the  manner  described  in the
Registration  Statement,   legally  and  validly  issued,  and  fully  paid  and
nonassessable.

      We hereby  consent  to the filing of this  opinion  as Exhibit  5.1 to the
Registration  Statement. In giving the foregoing consent, we do not hereby admit
that we are in the category of persons whose consent is required under Section 7
of the  Act,  or the  rules  and  regulations  of the  Securities  and  Exchange
Commission.

                                            Very truly yours,

                                            /s/ Stevens and Lee
                                            -------------------------
                                            Stevens and Lee


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