EXHIBIT 5 July 2, 1999 Board of Directors Focus Enhancements, Inc. 600 Research Drive Wilmington, Massachusetts 01887 Re: Registration Statement on Form S-3 of 402,796 shares of Common Stock, par value $0.01 per share Gentlemen: In connection with the registration under the Securities Act of 1933, as amended (the "Act"), by Focus Enhancements, Inc., a Delaware corporation (the "Company"), of 402,796 shares (the "Registered Shares") of its Common Stock, par value $.01 per share ("Common Stock"), all of which Registered Shares are to be offered for the account of certain selling stockholders of the Company, the following opinion is furnished to you to be filed with the Securities and Exchange Commission (the "Commission") as Exhibit 5 to the Company's registration statement on Form S3 (the "Registration Statement") under the Act. To the extent that any of the Registered Shares have not yet been issued, I assume that at the time of the issuance of such Registered Shares, there will exist, under the Company's Certificate of Incorporation, as amended (the "Certificate"), the requisite number of authorized shares of Common Stock for such issuance which are unissued, or held as treasury shares, and are not otherwise reserved for issuance. I am General Counsel and Secretary of the Company and I have examined originals or copies, certified or otherwise identified to my satisfaction, of the Registration Statement, the Certificate and the by-laws of the Company, certain Action of the Board of Directors by Unanimous Written Consent dated as of February 22, 1999, certain Action of the Board of Directors by Unanimous Written Consent dated as of July 29, 1999 and such other corporate records, certificates and statements of officers and accountants of the Company and of public officials and other documents as I have considered necessary or appropriate in order to furnish the opinion hereinafter set forth. This opinion is limited to the laws of the Commonwealth of Massachusetts and I express no opinion with respect to the law of any other jurisdiction. Based upon and subject to the foregoing, I hereby advise you that, in my opinion, (i) those Registered Shares that have been issued as of the date hereof were duly authorized and have been validly issued and are fully paid and nonassessable and (ii) those Registered Shares that may be issued after the date -2- hereof shall be, upon such issuance, duly authorized and validly issued and shall be fully paid and nonassessable. I hereby consent to the filing of this opinion as an exhibit to the Registration Statement. In giving this consent, I do not hereby admit that I come within the category of persons whose consent is required under Section 7 of the Act or the rules and regulations of the Commission promulgated thereunder. This opinion may not be referred to or used for any other purpose or in any other context or otherwise relied upon by any other person or entity without my express written consent. Respectfully, /s/ Christopher P. Ricci Christopher P. Ricci Sr. V.P. & General Counsel