Exhibit 5.1

                                   Law Offices
                               GREENE & LEE, P.L.
                       111 NORTH ORANGE AVENUE, SUITE 1450
                             ORLANDO, FLORIDA 32801
                            TELEPHONE: (407) 648-1700
                            FACSIMILE: (407) 648-0071
                        ---------------------------------
                                2982 PARK AVENUE
                           TALLAHASSEE, FLORIDA 32301
                            TELEPHONE: (850) 445-0695


                                 January 5, 2006

Board of Directors
Emerging Markets Holdings, Inc. 309 Celtic Court
Oviedo, Florida 32765

Re: Emerging Markets Holdings, Inc.

Gentlemen:

         We have acted as counsel for Emerging Markets Holdings, Inc., a Florida
corporation (the "Company"), in connection with the preparation and filing by
the Company of a registration statement on Form SB-2 (the "Registration
Statement") with the United States Securities and Exchange Commission under the
Securities Act of 1933, as amended (the "Securities Act"), covering up to
5,000,000 Units, each Unit consisting of one share of common stock, par value
$.0001 ("Common Stock"), to be sold to the public through Pacific Stock Transfer
Company ("Pacific"), as transfer agent.

         We have reviewed the Registration Statement and have examined such
other documents, and considered such matters of law, as we have deemed necessary
or appropriate for purposes of this opinion. We have assumed the genuineness of
all signatures on all documents reviewed by us, the authenticity of all
documents submitted to us as originals, and the conformity to authentic
originals of all documents submitted to us as copies. As to any facts material
to such opinion, we have, to the extent that relevant facts were not
independently established by us, relied on certificates of public officials and
certificates, oaths and declarations of officers or other representatives of the
Company.

         Based upon and subject to the foregoing, we are of the opinion that,
when the Registration Statement has become effective, the Units, when issued by
the Company and paid for in the manner contemplated by the prospectus contained
in the Registration Statement, will be legally issued, fully paid and
nonassessable.

         The opinions set forth herein are rendered as of the date hereof and
are based solely upon the Florida Business Corporation Act. We consent to the
reference to our Firm wherever appearing in the Registration Statement and to
the inclusion of this opinion as an exhibit to the Registration Statement. In
giving such consent, we do not admit hereby that we come within the category of
persons whose consent is required under Section 7 of the Securities Act or the
rules and regulations promulgated thereunder.

                                                 Respectfully submitted,

                                                 /s/ Green & Lee, P.L.
                                                 GREEN & LEE, P.L.

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