EXHIBIT 5.1

                       SICHENZIA ROSS FRIEDMAN FERENCE LLP
                     1065 Avenue of the Americas, 21st Floor
                            New York, New York 10018

                            Telephone: (212) 930-9700
                            Facsimile: (212) 930-9725


                                October 27, 2003


VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re: Sun Network Group, Inc.


Form SB-2 Registration Statement registering 301,500,000 shares of common stock
File No. 333-102693


Ladies and Gentlemen:

We refer to the above-captioned registration statement on Form SB-2 (the
"Registration Statement") under the Securities Act of 1933, as amended (the
"Act"), filed by Sun Network Group, Inc., a Florida corporation (the "Company"),
with the Securities and Exchange Commission.

We have examined the originals, photocopies, certified copies or other evidence
of such records of the Company, certificates of officers of the Company and
public officials, and other documents as we have deemed relevant and necessary
as a basis for the opinion hereinafter expressed. In such examination, we have
assumed the genuineness of all signatures, the authenticity of all documents
submitted to us as certified copies or photocopies and the authenticity of the
originals of such latter documents.

Based on our examination mentioned above, we are of the opinion that the
securities being registered to be sold pursuant to the Registration Statement
are duly authorized and will be, when sold in the manner described in the
Registration Statement, legally and validly issued, and fully paid and
non-assessable.

We hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement and to the reference to our firm in the section "Legal
Matters" in the Registration Statement. In giving the foregoing consent, we do
not hereby 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
Securities and Exchange Commission.

Very truly yours,

/s/ Sichenzia Ross Friedman & Ference LLP
    Sichenzia Ross Friedman & Ference LLP