AMY TROMBLY, ESQ.
                                 80 Dorcar Road
                          Newton, Massachusetts  02459
                                 (617) 243-0850
                                February 12, 2004

Utah  Clay  Technology,  Inc.
404  East  1st  Street,  Suite  1345
Long  Beach  California  90802

Re:  Registration  Statement  on  Form  S-8

Gentlemen:

I  have  acted as counsel to NeWave, Inc., a Utah corporation (the
"Company"),  in  connection  with the preparation and filing with the Securities
and  Exchange  Commission  of  a  Registration  Statement  on  Form  S-8  (the
"Registration  Statement"),  pursuant  to  which  the Company is registering the
issuance  under  the  Securities  Act of 1933, as amended, of a total of 800,000
shares (the "Shares") of its common stock, (the "Common Stock"). This opinion is
being  rendered in connection with the filing of the Registration Statement. All
capitalized  terms  used  herein  and  not  otherwise  defined  shall  have  the
respective  meanings  given  to  them  in  the  Registration  Statement.

In  connection  with  this  opinion,  I  have examined the Company's Articles of
Incorporation,  as  amended,  and By-laws, both as currently in effect, and such
other  records  of  the corporate proceedings of the Company and certificates of
the  Company's officers as I deemed relevant; and the Registration Statement and
the  exhibits  thereto.

In  my  examination, I have assumed the genuineness of all signatures, the legal
capacity  of  natural persons, the authenticity of all documents submitted to me
as originals, the conformity to original documents of all documents submitted to
me  as  certified or photostatic copies and the authenticity of the originals of
such  copies.

Based upon the foregoing, I am of the opinion that (i) the Shares have been duly
and  validly authorized by the Company and (ii) the Shares, when sold, will have
been  duly  and  validly  issued, fully paid and non-assessable shares of Common
Stock.

My  opinion is limited to the Utah Revised Business Corporation  Act and federal
securities  laws  of  the United States and I express no opinion with respect to
the  laws of any other jurisdiction. No opinion is expressed herein with respect
to  the qualification of the Shares under the securities or blue sky laws of any
state  or  any  foreign  jurisdiction.

I  understand  that  you  wish  to  file  this  opinion  as  an  exhibit  to the
Registration  Statement,  and  I  hereby  consent  thereto.

Very  truly  yours,

/s/  Amy  Trombly,  Esq.
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Amy  Trombly,  Esq.