EXHIBIT 5.1

                           [LETTERHEAD OF LOEB & LOEB]


Direct Dial: 310-282-2350
e-mail: dficksman@loeb.com


                                November 6, 2003

GPS Industries, Inc.
5500-152nd Street, Suite 214
Surrey, BC Canada V35 8E7

Ladies and Gentlemen:

         We have acted as counsel to GPS Industries, Inc., a Nevada Corporation
(the "Company"), in connection with the preparation and filing with the
Securities and Exchange Commission under the Securities Act of 1933, as amended,
(the "Act") of a Registration Statement on Form S-8 (the "Registration
Statement"), relating to the proposed sale by certain shareholders of the
Company (the "Selling Stockholders") of up to 40,000,000 shares of its Common
Stock (the "Common Stock") reserved for issuance under the 2000 Stock Option
Plan as amended by Amendment No. 1 dated as of November 6, 2003 and the 2001
Stock Compensation Plan as amended by Amendment No. 2 dated as of November 6,
2003.

         In so acting, we have examined and relied upon the originals or copies,
certified or otherwise identified to our satisfaction, of such Company records,
documents, certificates and other instruments as in our judgment are necessary
or appropriate to enable us to render the opinions expressed below. Based upon
the foregoing and such examination of law as we have deemed necessary, we are of
the opinion that the Common Stock to be offered by the Selling Stockholders,
when sold under the circumstances contemplated in the Registration Statement,
will be legally issued, fully paid and non-assessable.

         We are not licensed to practice law in the State of Nevada and
accordingly, with your permission, we express no opinion as to the laws of the
State of Nevada. Accordingly, the opinions we express herein are limited to
matters involving the federal laws of the United States.

         We consent to the use of this letter as an Exhibit to the Registration
Statement and to the use of our name under the heading "Legal Matters" included
in the Prospectus forming a part of the Registration Statement.

                                                     Sincerely,
                                                 /s/ David L. Ficksman
                                                     -----------------------
                                                     David L. Ficksman
                                                     a Partner of the Firm