Exhibit 5.1

                       [LATHAM & WATKINGS LLP LETTERHEAD]

                                 January 5, 2005

The Bluebook International Holding Company
21098 Bake Parkway, Suite 100
Lake Forest, CA 92630-2163


            Re:   Registration Statement on Form SB-2 for up to 2,557,239 shares
                  of common stock of the Company, $.0001 par value per share

Ladies and Gentlemen:

      We have acted as special  counsel to The  Bluebook  International  Holding
Company, a Delaware  corporation (the "Company"),  in connection with the filing
of a  registration  statement on Form SB-2 under the  Securities Act of 1933, as
amended (the "Act"),  filed with the  Securities  and Exchange  Commission  (the
"Commission") on January __, 2005 (the "Registration  Statement") registering up
to 2,557,239  shares (the  "Shares") of common stock of the Company,  $.0001 par
value per share (the "Common  Stock").  The shares being  registered are offered
for resale by the selling stockholders  identified in the Registration Statement
(the "Selling  Stockholders") and include:  (a) 2,131,033 shares of Common Stock
(the  "Common  Shares")  issued to the  Selling  Stockholders  pursuant  to that
certain Securities Purchase Agreement dated as of November 12, 2004 by and among
the Company and the Selling Stockholders, and (b) 426,206 shares of Common Stock
(the "Warrant Shares") which may be issued to the Selling  Stockholders upon the
exercise  of  warrants  dated as of  November  17,  2004,  issued to the Selling
Stockholders  (the  "Warrants").  This opinion is being  furnished in accordance
with the  requirements of Item 601(b)(5) of Regulation S-B under the Act, and no
opinion is expressed  herein as to any matter  pertaining to the contents of the
Registration Statement, other than as to the validity of the Shares.

      As such  counsel,  we have  examined such matters of fact and questions of
law as we have  considered  appropriate  for purposes of this letter.  With your
consent,  we have  (a)  assumed  that  proceedings  proposed  to be taken by the
Company in connection  with the  authorization,  issuance and sale of the Shares
will be  timely  completed  in the  manner  proposed,  and (b)  relied  upon the
foregoing and upon  certificates and other assurances of officers of the Company
and  others as to  factual  matters;  we have not  independently  verified  such
factual matters.

      In our  examination,  we assumed the  genuineness of all  signatures,  the
authenticity of all documents  submitted to us as originals,  and the conformity
to authentic original documents of all documents submitted to us as copies.

      We are  opining  herein only as to the  validity  of the Shares  under the
General  Corporation Law of the State of Delaware and we express no opinion with
respect to the applicability thereto, or the effect thereon, of any other laws.




      Subject to the foregoing, it is our opinion that as of the date hereof:

      1. The Common Shares have been duly authorized by all necessary  corporate
action of the Company, and are validly issued, fully paid and nonassessable; and

      2. The Warrant Shares have been duly authorized by all necessary corporate
action of the  Company,  and upon due and proper  exercise  of the  Warrants  in
accordance  with the terms of the  Warrants and  issuance,  delivery and payment
therefor  in the manner  contemplated  by the  Registration  Statement,  will be
validly issued, fully paid and nonassessable.

      We consent to your filing this  opinion as an exhibit to the  Registration
Statement and to the reference to our firm in the  Prospectus  under the heading
"Legal Matters." In giving such consent,  we do not thereby admit that we are in
the category of persons whose consent is required  under Section 7 of the Act or
the rules and regulations of the Commission thereunder.



                                                     Very truly yours,

                                                     /s/ Latham & Watkins LLP