EXHIBIT 5

                              Jackson Walker L.L.P.
                           901 Main Street, Suite 6000
                               Dallas, Texas 75202



                                   May 3, 2004



Boulder Acquisitions, Inc.
12890 Hilltop Road
Argyle, Texas 76226

        Re:   Registration Statement on Form S-8
              Employee Compensation Plan

Gentlemen:

         We have acted as counsel for Boulder Acquisitions, Inc. (the "Company")
in connection with the  Registration  Statement on Form S-8 filed by the Company
with the Securities and Exchange Commission to effect the registration, pursuant
to the  Securities  Act of 1933, of 100,000  shares of common stock,  $0.001 par
value  (the  "Common  Stock"),  which may be offered  by the  Company  under the
above-referenced plan (the "Plan").

         In connection with this opinion,  we have relied as to matters of fact,
without investigation, upon certificates of public officials and others and upon
affidavits, certificates and statements of directors, officers and employees of,
and the accountants for, the Company. We also have examined originals or copies,
certified or otherwise  identified to our  satisfaction,  of such  corporate and
other  instruments,  documents  and  records  as we  have  deemed  relevant  and
necessary to examine for the purpose of this  opinion,  including  the Plan.  In
addition, we have reviewed such questions of law as we have considered necessary
and appropriate for the purposes of this opinion.

         We have assumed the  accuracy and  completeness  of all  documents  and
records  that we have  reviewed,  the  genuineness  of all  signatures,  the due
authority  of the  parties  signing  such  documents,  the  authenticity  of all
documents submitted to us as originals,  the conformity to original documents of
all the  documents  submitted to us as certified or  photostatic  copies and the
authenticity of the originals of such latter documents.

         Based upon and  subject to the  foregoing,  we advise you that,  in our
opinion, the shares of Common Stock proposed to be offered by the Company as set
forth in the  Registration  Statement have been duly authorized and, when issued
and sold in accordance with the Plan referred to in the Registration  Statement,
such shares will be validly issued, fully paid and nonassessable.






         We hereby  consent to the  filing of this  opinion as an exhibit to the
above-referenced  Registration  Statement.  In giving  this  consent,  we do not
hereby  admit that we are in the category of persons  whose  consent is required
under Section 7 of the  Securities  Act of 1933 or the rules and  regulations of
the Securities and Exchange Commission.

         We express no opinions as to matters  under or involving any laws other
than  the  federal  laws  of the  United  States  of  America  and  the  General
Corporation Law of the State of Nevada.

                                                          Very truly yours,



                                                          /s/ Jackson Walker
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