FOLEY & LARDNER LLP
                                                      ATTORNEYS AT LAW

                                                      777 EAST WISCONSIN AVENUE
                                December 5, 2005      MILWAUKEE, WI  53202-5306
                                                      414.271.2400 TEL
                                                      414.297.4900 FAX
                                                      www.foley.com

                                                      CLIENT/MATTER NUMBER
                                                      055573-0101

Rydex Specialized Products LLC,
  d/b/a Rydex Investments
9601 Blackwell Road
Suite 500
Rockville, MD 20850

          Re:  Euro Currency Trust

Ladies and Gentlemen:

     We have acted as legal counsel to Rydex Specialized Products LLC, a
Delaware limited liability company d/b/a Rydex Investments (the "Company"), in
connection with the preparation and filing under the Securities Act of 1933, as
amended (the "Securities Act"), and the rules and regulations of the Securities
and Exchange Commission (the "SEC") promulgated thereunder, of a registration
statement on Form S-1, Registration No. 333-125581, initially filed on June 7,
2005, as amended through the date hereof (the "Registration Statement"). The
Registration Statement relates to the proposed issuance by the Euro Currency
Trust (the "Trust"), an investment trust formed on December 2, 2005 under the
laws of the state of New York pursuant to the terms of the Trust Agreement dated
December 2, 2005 (the "Trust Agreement") between the Company, as sponsor, and
The Bank of New York, a banking corporation organized under the laws of the
State of New York, as trustee (the "Trustee"), of 150,000 shares, representing
units of fractional undivided beneficial interest in and ownership of the Trust
(the "Shares"). In connection with the issuance of the Shares, you have
requested our opinion with respect to certain U.S. federal tax matters.
Capitalized terms not otherwise defined herein shall have the meanings given to
them in the Trust Agreement.

     In rendering the opinion expressed below, we have examined and relied on
the Registration Statement and originals or copies, certified or otherwise
identified to our satisfaction, of the Trust Agreement and all such other
documents as we have deemed necessary or appropriate in order to enable us to
render the opinion expressed below.

     In our examination of the foregoing documents, we have assumed, with your
consent: that all documents reviewed by us are original documents, or true and
accurate copies of original documents and have not subsequently been amended;
that the signatures on each original document are genuine; that each party who
executed the document had proper authority and capacity; that all factual
representations and statements set forth in such documents are true and correct;
and that all obligations imposed by any such documents on the parties thereto
have been or will be performed or satisfied in accordance with their terms.

     Our opinion is based upon the Internal Revenue Code of 1986, as amended,
the Treasury Regulations promulgated thereunder, judicial decisions, current
rulings and pronouncements of the Internal Revenue Service (the "IRS"), and such
other authorities as we have considered relevant, in effect as of the date of
this letter, all of which are subject to legislative, judicial or administrative



BOSTON        JACKSONVILLE    NEW YORK      SAN DIEGO/DEL MAR   TAMPA
BRUSSELS      LOS ANGELES     ORLANDO       SAN FRANCISCO       TOKYO
CHICAGO       MADISON         SACRAMENTO    SILICON VALLEY      WASHINGTON, D.C.
DETROIT       MILWAUKEE       SAN DIEGO     TALLAHASSEE         WEST PALM BEACH




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Rydex Specialized Products LLC
December 5, 2005
Page 2

change or differing interpretation, possibly with retroactive effect. Our
opinion is not binding on the IRS, and no assurance can be given that the
conclusions expressed herein will not be challenged by the IRS or sustained by a
court.

     Based upon and subject to the foregoing, we confirm that the discussion in
the Registration Statement under the caption "United States Federal Tax
Consequences," to the extent it consists of statement of law and legal
conclusions, and subject to the limitations and qualifications set forth
therein, constitutes our opinion as to the material U.S. federal tax
consequences that apply under currently applicable law to the purchase,
ownership and disposition of the Shares.

     The opinion referred to above represents our best legal judgment as to the
application of the U.S. federal tax laws existing as of the date of this letter.
Further, the opinion referred to above is based upon the assumptions, documents,
facts and representations referred to above. Any material amendments to such
documents, changes in any significant facts or inaccuracy of such assumptions or
representations could affect the accuracy of our opinion. Although we have made
such inquiries and performed such investigations as we have deemed necessary to
fulfill our professional responsibilities as counsel, we have not undertaken an
independent investigation of all the relevant facts. Our opinion is based solely
upon the law and the facts as they exist on the date hereof; and we disclaim any
obligation to advise you of any subsequent change in law or facts or
circumstances that might subsequently come to our attention.

     We hereby consent to the filing of this opinion letter as an exhibit to the
Registration Statement and to the use of our name where it appears in the
Registration Statement. In giving this consent, we do not admit that we are
within the category of persons whose consent is required by Section 7 of the Act
or the rules and regulations of the SEC promulgated thereunder. This opinion
only relates to the issuance and sale of the Shares pursuant to the Registration
Statement and may not be relied upon by you or any other person for any other
purpose, without our prior written consent in each instance.

                                            Very truly yours,

                                            FOLEY & LARDNER LLP

                                            /s/ FOLEY & LARDNER LLP