VIA EDGAR

April 18, 2005

Board of Directors
Nationwide Life Insurance Company
One Nationwide Plaza
Columbus, Ohio 43215

         Re:      Guaranteed Term Options
                  Nationwide Life Insurance Company
                  SEC File No. 333-104106

Ladies and Gentlemen:

I am furnishing this opinion in connection with the registration, under the
Securities Act of 1933, as amended, of Guaranteed Term Options (GTOs) that
Nationwide Life Insurance Company (Nationwide) continuously offers and sells. I
have examined Post-effective Amendment No. 5 to the Registration Statement on
Form S-2, and related documents, and I have reviewed the questions of law I
considered necessary and appropriate. On the basis of this examination and
review, it is my opinion that:

1.       Nationwide is a corporation duly organized and validly existing as a
         stock life insurance company under the laws of the State of Ohio, and
         is duly authorized by the Insurance Department of the State of Ohio to
         issue the GTOs.

2.       Nationwide has filed the form of the GTO contract in the states where
         it is eligible for approval. Upon issuance, the GTO contract will be a
         valid and binding obligation of Nationwide.

I hereby consent to the use of this opinion as an exhibit to this registration
statement.

Sincerely,

/s/ Paige L. Ryan

Paige L. Ryan
Senior Counsel