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                                                                     EXHIBIT 5.1


                      [CAIRNCROSS & HEMPELMANN, P.S. LETTERHEAD]


                                August 8, 1997


fine.com Corporation
1118 Post Avenue
Seattle, Washington  98101

         Re:     Registration Statement on Form SB-2

Ladies and Gentlemen:

     fine.com Corporation, a Washington corporation (the "Company"), has
requested that we furnish an opinion, as set forth herein, with respect to
certain matters in connection with the offering of up to 1,265,000 shares of the
Company's common stock, no par value (the "Shares"), (which includes 165,000
Shares subject to an option granted to the several underwriters of such
offering solely to cover over-allotments, if any) as well as up to 110,000
additional shares of such common stock underlying certain warrants (the
"Representative's Warrants") to be issued to the representative of the several
underwriters for the offering, pursuant to the prospectus (the "Prospectus")
included in the Company's registration statement on Form SB-2, as amended (File
No. 333-26855) (the "Registration Statement"). 

     We have acted as counsel for the Company in connection with the offering
and sale of the Shares.  In the course of such representation, our firm assisted
the Company in the preparation of the Registration Statement and related
documents and correspondence. In connection with the opinions expressed herein,
we have reviewed the Company's Articles of Incorporation, as amended, Bylaws,
form of Representative's Warrant Agreement, minutes of meetings of and action of
the Board of Directors and the Company's shareholders and other relevant
documents we deemed necessary. This letter should be read in conjunction with
the Prospectus and, unless the context hereof clearly otherwise provides, all
capitalized terms herein shall have the respective meanings ascribed thereto in
the Prospectus.

     On the basis of the foregoing, and subject to the qualifications set forth
herein, we are of the opinion that (a) the Shares have been duly authorized,
and, upon the issuance and sale thereof by the Company as described in the
Registration Statement, and the receipt of the consideration therefor as
described therein, the Shares will be validly issued, fully paid and
non-assessable, and (b) the Representative's Warrants and the shares to be
issued upon exercise of the Representative's Warrants, when issued in exchange
for the consideration recited therein, will be legally issued, fully paid and
non-assessable.  This opinion does not address the compliance, or lack thereof,
of the offering or such issuance and sale with any securities laws or any law or
statute other than the Washington Business Corporation Act (Title 23B of the
Revised Code of Washington).


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        We hereby consent to the reference to our firm under "Legal Matters" in 
the Prospectus and to the inclusion of this letter as Exhibit 5.1 to the
Registration Statement.


                                                   Very truly yours,

                                             /s/   CAIRNCROSS & HEMPELMANN, P.S.