Exhibit  5.1      Opinion  of     Weed  &  Co.  LLP

September  27,  2006

Board  of     Directors
Island  Residences  Club,  Inc.
1769-203  Jamestown  Road
Williamsburg,  VA  23185

Re:  Form  SB-2  Registration  Statement,  Opinion  and  Consent  of  Counsel

Dear     Members  of     the  Board:


We  have  acted  as  counsel  to Island Residences Club, Inc. (the "Company") in
connection  with  the  registration under the Securities Act of 1933, as amended
(the  "Act"),  of  an  aggregate  of  14,737,000  shares  (the  "Shares") of the
Company's  common  stock, par value $.0001 per share (the "Common Stock"), to be
sold  by  the  selling stockholders upon the terms and subject to the conditions
set  forth in the Company's registration statement on Form SB-2, as amended (the
"Registration  Statement").

In connection therewith, we have examined copies of the Company's Certificate of
Incorporation  and Bylaws, as amended, the corporate proceedings with respect to
the Shares, and such other documents and instruments as we have deemed necessary
or  appropriate  for  the  expression  of the opinions contained herein. In such
examination, we have assumed the genuineness of all signatures, the authenticity
and  completeness  of all documents submitted to us as originals, the conformity
to  the  original  documents  of all documents submitted to us as copies and the
correctness  of  all  statements  of  fact  contained  in  such  documents.

Based  on  the  foregoing, and having regard for such legal considerations as we
have  deemed  relevant,  we are of the opinion that the Shares to be sold by the
selling  stockholders  by  means  of  the  Registration  Statement, when sold in
accordance  with  the  terms  and  conditions  set  forth  in  the  Registration
Statement,  will  be  legally  issued,  fully  paid  and  non-assessable.

We  consent  to  the  filing  of  this opinion as an exhibit to the Registration
Statement  and  to  the  use  of  our  name under the caption "Interest of Named
Experts  and  Counsel" in the prospectus included in the Registration Statement.

Very  truly  yours,

/s/Weed & Co.  LLP
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   Weed & Co.  LLP