Exhibit 5

September 27, 2007

Cinemark Holdings, Inc.
3900 Dallas Parkway, Suite 500
Plano, Texas 75093

Re:       Cinemark Holdings, Inc.
           Registration Statement on Form S-8

Ladies and Gentlemen:

     We have acted as counsel to Cinemark Holdings, Inc., a Delaware corporation (the “Company”), in connection with the preparation and filing by the Company with the Securities and Exchange Commission of a Registration Statement on Form S-8 (the “Registration Statement”), under the Securities Act of 1933, as amended (the “Act”). The Registration Statement relates to the offer and sale by the Company of up to 9,077,370 shares (the “Shares”) of the Company’s common stock, par value $0.001 per share (“Common Stock”), issuable under the Cinemark Holdings, Inc. 2006 Long Term Incentive Plan, as such plan is described in the Registration Statement (the “Plan”). This opinion is being furnished in accordance with the requirements of Item 601(b)(5) of Regulation S-K under the Act.

     We have examined originals or certified copies of such corporate records of the Company and other certificates and documents of officials of the Company, public officials and others as we have deemed appropriate for purposes of this letter. We have assumed the genuineness of all signatures, the legal capacity of all natural persons, the authenticity of all documents submitted to us as originals and the conformity to authentic original documents of all copies submitted to us as conformed, certified or reproduced copies. As to various questions of fact relevant to this letter, we have relied, without independent investigation, upon certificates of public officials and certificates of officers of the Company, all of which we assume to be true, correct and complete.

     Based upon the foregoing, and subject to the assumptions, exceptions, qualifications and limitations stated herein, we are of the opinion that when the Registration Statement has become effective under the Act and when the Shares have been issued, sold and delivered in compliance with the Plan and applicable federal and state securities laws and in the manner described in the Registration Statement, the Shares will be duly authorized, validly issued, fully paid and non-assessable.

     The opinions and other matters in this letter are qualified in their entirety and subject to the following:

1700 Pacific Avenue, Suite 4100 / Dallas, Texas 75201-4675 / 214.969.2800 / fax: 214.969.4343 / akingump.com

Cinemark Holdings, Inc.
September 27, 2007
Page 2

	A.		We express no opinion as to the laws of any jurisdiction other than the General Corporation Law of the State of Delaware.
	B.		This opinion letter is limited to the matters expressly stated herein and no opinion is to be inferred or implied beyond the opinion expressly set forth herein. We undertake no, and hereby disclaim any, obligation to make any inquiry after the date hereof or to advise you of any changes in any matter set forth herein, whether based on a change in the law, a change in any fact relating to the Company or any other person or any other circumstance.

     We hereby consent to the filing of this opinion letter as an exhibit to the Registration Statement. In giving this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Act and the rules and regulations thereunder.

		Very truly yours,
		/s/ AKIN, GUMP, STRAUSS, HAUER & FELD, L.L.P.
		AKIN, GUMP, STRAUSS, HAUER & FELD, L.L.P.