EXHIBIT 5.1 LEGAL OPINION OF LAW OFFICES OF HAROLD H. MARTIN, P.A.

                      LAW OFFICES OF HAROLD H. MARTIN, P.A.
        21311 Catawba Avenue, Suite 300, Cornelius, North Carolina 28031
                TELEPHONE (704) 894-9760 FACSIMILE (704) 894-9759

                                December 1, 2003

Board of Directors
Hairmax International Corp.
4810 W. Commercial Blvd.
Ft. Lauderdale, FL 33319

     Re:  Form S-8 Registration Statement; Opinion of Counsel

Dear Members of the Board:

You have requested our opinion with respect to certain matters in connection
with Hairmax International Corp.'s (the "Company") filing of a registration
statement on Form S-8 (the "Registration Statement") with the Securities and
Exchange Commission covering the offering of an aggregate of 2,000,000 shares of
the Company's common stock, $.001 par value (the "Shares"), pursuant to the 2003
Non-Qualified Stock Compensation Plan (the "Stock Plan").

In connection with this opinion, we have examined the Registration Statement and
such other documents, records, certificates, memoranda and other instruments as
we deemed necessary for the basis of this opinion. We have assumed the
genuineness and authenticity of all documents submitted to us as originals and
the conformity to originals of all documents submitted to us as copies and the
due execution and delivery of all documents where due execution and delivery are
a prerequisite to the effectiveness thereof.

On the basis of the foregoing, and in reliance thereon, we are of the opinion
that the Shares, when sold and issued in accordance with the Stock Plan and
related consulting agreements and the Registration Statement and related
prospectus, will be legally issued, fully paid and non-assessable.

We  consent to the use of our opinion as an exhibit to the Form S-8 Registration
Statement  and  to  the  reference  to  this  firm  in  any  prospectus which is
incorporated  by  reference  into and made a part of the Registration Statement.
However,  we  do  not  hereby admit that we come within the category of a person
whose  consent  is  required  under  Section 7 of the Securities Act of 1933, as
amended,  or  the  general  rules  or  regulations  thereunder.

                                     Very truly yours,

                                     Law Offices of Harold H. Martin, P.A.
                                 By: /s/ Harold H. Martin
                                     --------------------
                                     Harold H. Martin