POULTON & YORDAN
                           ATTORNEYS AT LAW
                    4 TRIAD CENTER, SUITE 500-A
                    SALT LAKE CITY, UTAH 84180




                              January 6, 1997



Board of Directors
Wild Wings, Inc.
899 Artistic Circle
Springville, Utah  84663

     RE:  Registration Statement on Form S-8

Gentlemen:

     We have acted as counsel to a Nevada corporation (the "Company"), in
connection with the preparation and filing of a Registration Statement on
Form S-8 (the "Registration Statement") filed with the Securities and
Exchange Commission on January 6, 1997 pertaining to 400,000 shares of the
Company's common stock, par value $.001 (the "Shares") being registered in
connection with the Company's "Wild Wings, Inc. 1995 Stock Option Plan",
(the "Plan").

     We have reviewed the Articles of Incorporation and Bylaws of the
Company, resolutions of the board of directors and shareholders of the
Company, the Registration Statement, the Plan and such other documents as
we have deemed appropriate.  As to factual matters we have relied
upon a certificate supplied to us by an officer of the Company.  In
rendering the opinion expressed herein, we have assumed, without
investigation, the validity of all documents and the accuracy of
all information supplied to us by the Company.

     Based upon the foregoing, we are of the opinion that the Shares
being registered pursuant to the Registration Statement, when the
Registration Statement becomes effective and the Shares are issued and
paid for in accordance with the Plan, will have been duly authorized and will be
legally issued, fully paid and non-assessable.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and the reference to this firm under "Legal Matters"
in the Prospectus contained in the Registration Statement.

                              Very truly yours,
                              POULTON & YORDAN


                              /s/ Cletha A. Walstrand