EXHIBIT 5.1

                    SICHENZIA ROSS FRIEDMAN FERENCE LLP 1065
                        Avenue of the Americas, 21st Flr.
                               New York, NY 10018

                            Telephone: (212) 930-9700
                            Facsimile: (212) 930-9725

                                November 12, 2004

VIA ELECTRONIC TRANSMISSION

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

RE:   SUNBURST ACQUISITION IV, INC.
      FORM SB-2 REGISTRATION STATEMENT (FILE NO. 333-__________)

Ladies and Gentlemen:

      We refer to the above-captioned  registration  statement on Form SB-2 (the
"Registration  Statement")  under the  Securities  Act of 1933,  as amended (the
"Act"),  filed by Sunburst  Acquisitions  IV, Inc., a Colorado  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 sold pursuant to the Registration  Statement,  including up to
27,000,000  shares of common  stock  underlying  convertible  debentures,  up to
34,861,095 shares of common stock underlying common stock purchase warrants,  up
to 27,000,000 shares of common stock underlying an additional  investment right,
are duly  authorized  and will be,  when issued in the manner  described  in the
Registration   Statement,   legally   and   validly   issued,   fully  paid  and
non-assessable.  Further,  we are of the opinion  that the  3,511,095  shares of
common stock held by the selling  stockholder are duly  authorized,  legally and
validly issued, fully paid and non-assessable.

      We hereby  consent  to the filing of this  opinion  as Exhibit  5.1 to the
Registration Statement and to the reference to our firm under "Legal Matters" in
the related Prospectus.  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.

/s/ Sichenzia Ross Friedman Ference LLP

Sichenzia Ross Friedman Ference LLP