Attached files

                                                                     Exhibit 5.1

May 15, 2011

Stepp Law Corporation
15707 Rockfield Blvd.
Suite 101
Irvine, California 92618
Telephone: 949.660.9700
Facsimile: 949.660.9010

Lisboa Leisure, Inc.
H 16/B, Adsulim
Benaulim, Goa, India 403716

Attention: Maria Fernandes

     Re: Lisboa Leisure, Inc., a Nevada corporation

Dear Ms. Fernandes:

     Lisboa Leisure, Inc., a Nevada corporation (the "Company"), has asked us to
provide our opinion  regarding  the legality of the sale of 1,600,000  shares of
the Company's $.001 par value common stock in connection  with the  registration
of those shares  pursuant to the Securities Act of 1933 (the  "Securities  Act")
for sale by the  Company  (the  "Registered  Shares"),  as  described  below.  A
registration  statement on Form S-1 has been prepared by the Company and will be
filed with the  Securities  and  Exchange  Commission  (the  "Commission")  (the
"Registration  Statement").  A copy of this  letter  shall  be  filed  with  the
Registration Statement.  The Registered Shares are to be offered for sale to the
public by the Company, without the use of any underwriters and at a fixed price.

     In connection with rendering the opinion  specified in this letter, we have
examined  copies  of  the  Registration  Statement  and  all  exhibits  thereto.
Additionally,  as for certain  factual matters only, we have examined and relied
upon the original, or copies certified to our satisfaction,  of (i) the Articles
of Incorporation and the Bylaws of the Company, (ii) records of the Company with
respect  to  the  issuance  of the  Registered  Shares,  and  (iii)  such  other
information  relating to the Company as we deemed  necessary or appropriate  for
purposes of the opinion specified in this letter. For purposes of providing that
opinion,  we have made such additional  investigation and inquiries  relevant to
the transactions  contemplated by the  Registration  Statement as we have deemed
necessary,  and  we  have  relied,  to  the  extent  we  deemed  reasonable,  on
certificates  and certain  other  information  provided to us by officers of the
Company as to matters  of fact of which the makers of such  certificates  or the
persons  providing such other  information  had knowledge and  information  made
available by public officials.

     Furthermore,  for purposes of providing that opinion,  we have assumed that
the  signatures  on all  documents  examined by us are  genuine,  all  documents
submitted  to us as  originals  are accurate  and  complete,  and all  documents
submitted to us as copies are true, correct and complete copies of the originals
thereof.

     Based on the foregoing,  it is our opinion that (i) the  Registered  Shares
have been duly and validly  authorized for issuance and (ii) at such time as the
Registration   Statement  is  declared  effective  by  the  Commission  and  the
Registered Shares sold pursuant to the provisions of the Registration Statement,
the Registered Shares will be validly issued, fully paid, and non-assessable.

     We  confirm  that we  furnish  no  opinion  with  respect  to the truth and
accuracy or the  completeness  of the  Registration  Statement,  other than this
letter. The opinion specified in this letter is expressly limited to the matters
specified in this letter, and we furnish no opinion,  express or implied,  as to
any other  matter  relating to the Company or its  securities.  Accordingly,  no
provision  of this  letter is  intended  to,  nor shall any such  provision,  be
construed as an opinion concerning any matter not specified in this letter.

     We consent to the (i) use of this letter as an exhibit to the  Registration
Statement,  (ii)  disclosure  in the  prospectus  portion  of  the  Registration
Statement of the opinion specified in this letter,  and (iii) use of our name 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  pursuant
to  Section  7 of the  Securities  Act,  or the  rules  and  regulations  of the
Commission.

     The Company is hereby advised,  urged,  and encouraged to consult with and,
if  appropriate,  retain  securities  counsel in each  jurisdiction  outside the
United States in which the  Registered  Shares may be offered and sold regarding
compliance with the securities laws of such jurisdiction.

     Finally,  of  course,  in the event  that you have  questions  or  comments
regarding this matter, please do not hesitate to contact us. Thank you.

Sincerely,

STEPP LAW CORPORATION


    /s/ Thomas E. Stepp, Jr.
    -----------------------------------
By: Thomas E. Stepp, Jr