Exhibit 5.1

THE THOMAS GROUP INTERNATIONAL
A PROFESSIONAL CORPORATION


October 31, 2002

Sun Network Group, Inc.
1440 Coral Ridge Drive, # 140,
Coral Springs, FL 33071

Ladies and Gentlemen:

We have acted as special counsel to Sun Network Group, Inc., a Florida
corporation (the "Company"), in connection with the Registration Statement on
Form SB-2 (the "Registration Statement") filed by the Company with the
Securities and Exchange Commission pursuant to the Securities Act of 1933,
relating to the offer and sale of up to 78,151,513 shares of common stock, par
value $.001 per share, of the Company (the "Common Shares"), that may be issued
upon conversion of certain warrants and convertible debentures pursuant to
certain warrant agreements and/or rights to conversion described therein. In
connection with this opinion, we have examined and are familiar with originals
or copies, certified or otherwise identified to our satisfaction, of such
documents, corporate records, minute books, certificates of public officials and
other instruments as we have deemed necessary or advisable in connection with
this opinion. In our examination we have assumed the genuineness of all
signatures the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as certified
or photostatic copies, the authenticity of originals of such copies and the
authenticity of telegraphic or telephonic confirmations of public officials and
others. As to facts material to our opinion, we have relied solely upon
certificates or telegraphic or telephonic confirmations of public officials and
certificates, documents, statements and other information provided by the
Company or its representatives or officers. Our examination of law relevant to
the matters covered by this opinion is limited to the laws of the State of
Florida and the federal law of the United States, and we express no opinion as
to the effect on the matters covered by this opinion of the laws of any other
jurisdiction. Based upon the foregoing, we are of the opinion that the Common
Shares to be issued by the Company upon the exercise of warrants and upon the
exercise of the convertible debentures described in the Registration Statement,
as applicable, when paid for and issued in accordance with the terms as
described in the Registration Statement, will be validly issued, fully paid and
non-assessable. We hereby consent to the filing of this opinion as an Exhibit to
the Registration Statement and to the reference to us under the caption "Legal
Matters" in the prospectus that is a part of the Registration Statement.

Very truly yours,

THE THOMAS GROUP INTERNATIONAL, PC

/s/ Stephen J. Thomas
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Stephen J. Thomas