EXHIBIT  5.1  LEGAL  OPINION  OF  LAW  OFFICES  OF  HAROLD  H.  MARTIN,  P.A.

                      LAW OFFICES OF HAROLD H. MARTIN, P.A.
        21311 Catawba Avenue, Suite 300, Cornelius, North Carolina 28031
                TELEPHONE (704) 894-9760 FACSIMILE (704) 894-9759

                                 April 13, 2004

Board  of  Directors
Hairmax  International,  Inc.
9900  West  Sample  Road
Coral  Springs,  Florida  33065

     Re:  Form  S-8  Registration  Statement;  Opinion  of  Counsel

Dear  Members  of  the  Board:

You  have  requested  our  opinion with respect to certain matters in connection
with  Hairmax  International,  Inc.'s  (the  "Company") filing of a registration
statement  on  Form  S-8  (the "Registration Statement") with the Securities and
Exchange Commission covering the offering of an aggregate of 6,000,000 shares of
the Company's common stock, $.001 par value (the "Shares"), pursuant to the 2004
Non-Qualified  Stock  Compensation  Plan  (the  "Stock  Plan").

In connection with this opinion, we have examined the Registration Statement and
such  other documents, records, certificates, memoranda and other instruments as
we  deemed  necessary  for  the  basis  of  this  opinion.  We  have assumed the
genuineness  and  authenticity of all documents submitted to us as originals and
the  conformity  to originals of all documents submitted to us as copies and the
due execution and delivery of all documents where due execution and delivery are
a  prerequisite  to  the  effectiveness  thereof.

On  the  basis  of the foregoing, and in reliance thereon, we are of the opinion
that  the  Shares,  when  sold  and issued in accordance with the Stock Plan and
related  consulting  agreements  and  the  Registration  Statement  and  related
prospectus,  will  be  legally  issued,  fully  paid  and  non-assessable.

We  consent to the use of our opinion as an exhibit to the Form S-8 Registration
Statement  and  to  the  reference  to  this  firm  in  any  prospectus which is
incorporated  by  reference  into and made a part of the Registration Statement.
However,  we  do  not  hereby admit that we come within the category of a person
whose  consent  is  required  under  Section 7 of the Securities Act of 1933, as
amended,  or  the  general  rules  or  regulations  thereunder.




                                 Very truly yours,

                                 /s/ Harold H. Martin
                                 --------------------
                                 Harold H. Martin
                                 Law Offices of Harold H. Martin, P.A.