EXHIBIT
5.1





Wohlforth |Johnson | Brecht
              Cartledge | Brooking
              
              A
      PROFESSIONAL CORPORATIONJulius
      J. Brecht
              Cheryl
      Rawls Brooking
              Cynthia
      L. Cartledge
              Michael
      Gatti
              Clyde
      W. Hutchins Jr.
              Robert
      M. Johnson
              Leila
      R. Kimbrell
              Eric
      E. Wohlforth
            ATTORNEYS
      AT LAW
              
              900
      WEST 5TH AVENUE, SUITE 600
              
              ANCHORAGE,
      ALASKA 99501-2048
            Telephone
              907.276.6401
              
              Facsimile
              907.276.5093
              
              Website
              www.akatty.com


August 7,
2008











Ronald A. Duncan,
President


General
Communication, Inc.


2550 Denali Street,
Suite 1000


Anchorage, Alaska
99503





Re:
            Opinion As To
      Legality of Shares To Be Issued Pursuant To General Communication, Inc.
      Qualified Employee Stock Purchase Plan; Our File No.
    0618.0637





Dear Mr.
Duncan:





You have requested
an opinion from this firm on behalf of General Communication, Inc. ("Company"),
in connection with 2,800,000 shares of Class A common stock of the Company
("Shares") to be allocated and issued in conjunction with the Company's revised
Qualified Employee Stock Purchase Plan ("Plan").





It is this firm's
understanding that the facts surrounding these proposed transactions are
represented by the Company as follows ("Facts"):





1.           The
Plan was adopted by the board of directors of the Company ("Board") by
resolution at its December 17, 1986 meeting called and conducted in accordance
with the Restated Articles of Incorporation and Bylaws of the Company
("Articles" and "Bylaws," respectively), and the Plan was approved by the
Company's then sole shareholder, Western Tele Communications, Inc., by
resolution at the Company's shareholder meeting held on December 17, 1986; and
the Plan was later amended by the Board on June 4, 1992 to comply with changes
to the federal Rule 16b-3; on March 24, 1993 the Board approved an increased
allocation of stock to the Plan in the amount of 700,000 shares of Class A
common stock and 100,000 shares of Class B common stock, on October 20, 1994 to
comply with the Internal Revenue Code of 1986, as amended, and The Plan was
amended by the Board to allow participating eligible employees to choose to
invest in securities other than the common stock of the Company; on February 9,
1995 the Board approved an increased allocation of stock to the Plan in the
amount of 800,000 shares of Class A common stock; on September 1, 1995 the Plan
was amended by the Board to comply with provisions of the Internal Revenue Code
of 1986, as amended, primarily related to investment responsibility and the
relationship between the Plan Committee and the Trustee; on June 25, 1998, the
Board approved amendments to the Plan dealing with hardship withdrawals and
rollover contributions; on October 30, 1998, the Board approved an increased
allocation of stock to the Plan in the amount of 2,000,000 shares of Class A and
400,000 shares of Class B common stock; on May 10, 2000, the Board approved an
increased allocation of stock to the Plan in the amount of 2,500,000 shares of
Class A common stock; on April 25, 2003 the Board approved an increased
allocation of stock to the Plan in the amount of 4,000,000 shares of Class A
common stock; on December 18, 2007 the Board approved a restatement of the plan
including amendment nos. 1-8 to it, i.e., the present version of the Plan; and
on April 25, 2008 the Board approved an increased allocation of stock to the
Plan in the form of the Shares, i.e., 2,800,000 shares of Class A common
stock;





2.           The
Articles provide that the Company has the power to issue and sell any stock and
further expressly provides for the issuance of Class A common stock and Class B
common stock;





3.           The
Plan provides for the acquisition of Class A and Class B common stock of the
Company by the Plan on behalf of qualified employees, and there are shares
available for issuance by the Company under the Plan and pursuant to the
Articles;





4.           The
material provisions of the Articles and Bylaws pertaining to the issuance of
Class A common stock in effect as of the date of this letter were those in
effect as of April 25, 2008;





5.           The
Company was incorporated as an Alaska corporation and received a Certificate of
Incorporation dated July 16, 1979 from the Alaska Department of Commerce and
Economic Development;





6.           The
Company is in good standing with respect to the reporting and corporation tax
requirements of the Alaska Corporations Code to which the Company is subject,
and the Company is otherwise validly existing as an Alaska corporation pursuant
to the laws of the State of Alaska with all requisite powers to own property and
to conduct its business in the manner contemplated by the Articles and
Bylaws;





Copies of the
Articles and Bylaws, as amended and revised, respectively, Certificate of
Incorporation, as restated, the above referenced resolutions, and the Plan have
been delivered to this firm.  We have reviewed these
documents.  The Articles provide that the Company is organized for the
purposes of transacting any and all lawful business for which corporations may
be incorporated under the Alaska Corporations Code.





Based upon the
foregoing Facts, we are of the opinion as follows.  Assuming due
compliance with applicable federal and state securities laws, (1) the Shares
will, when issued through the Plan, represent newly created and legally issued,
fully paid, and non assessable shares of Class A common stock in the Company and
(2) each holder of a Share will be entitled to the benefits of a shareholder pro
rata based on ownership of outstanding shares of the respective class of common
stock of the Company.





This letter must
not be quoted or referred to in the Company's financial statements or provided
to persons other than the officers and directors of the Company without prior
consultation with us or our prior written consent.  The firm is aware
of the Company's intent to and consents to the use of this letter as an exhibit
in an amendment to Form S 8 registration with the Securities and Exchange
Commission pertaining to the Shares to be allocated to the Plan.





Sincerely,





WOHLFORTH, JOHNSON, BRECHT,


CARTLEDGE & BROOKING





/s/ Julius J. Brecht





Julius J. Brecht