KRYS BOYLE FREEDMAN & SAWYER, P.C.
                               Attorneys at Law
TELEPHONE                   Suite 2700 South Tower                  FACSIMILE
(303) 893-2300              600 Seventeenth Street             (303) 893-2882
                          enver, Colorado 80202-5427


                                June 8, 1999

ecom ecom.com, inc.
8125 Monetary Drive, Suite H4
Riviera Beach, Florida  33404

     Re: SEC Registration Statement on Form S-8

Gentlemen:

     We are counsel for ecom ecom.com, inc., a Florida corporation (the
"Company") in connection with its registration under the Securities Act of
1933, as amended (the "Act"), of 100,000,000 shares of common stock which may
be issued upon the exercise of options granted under the Company's First Stock
Incentive Stock Plan through a Registration Statement on Form S-8 as to which
this opinion is a part, to be filed with the Securities and Exchange
Commission (the "Commission").

     In connection with rendering our opinion as set forth below, we have
reviewed and examined originals or copies identified to our satisfaction of
the following:

     (1)  Articles of Incorporation of the Company as filed with the
Secretary of State of the State of Florida, as amended.

     (2)  Minute book containing the written deliberations and resolutions
of the Board of Directors and Shareholders of the Company.

     (3)  The Registration Statement.

     (4)  The exhibits to the Registration Statement to be filed with the
Commission.

     We have examined such other documents and records, instruments and
certificates of public officials, officers and representatives of the Company,
and have made such other investigations as we have deemed necessary or
appropriate under the circumstances.


     Based upon the foregoing and in reliance thereon, it is our opinion that
the 1,000,000,000 shares of the Company's $.0001 par value common stock which
may be issued upon the exercise of  options under the Incentive Stock Option
Plan will, upon the purchase, receipt of full payment, issuance and delivery
in accordance with the terms of such options, be duly and validly authorized,
legally issued, fully paid and non-assessable.





     We hereby consent to the filing of this opinion as an exhibit to the
referenced Registration Statement on Form S-8.

                                     Very truly yours,

                                     KRYS BOYLE FREEDMAN & SAWYER, P.C.


                                     By /s/ Stanley F. Freedman, P.C.
                                        Stanley F. Freedman, P.C.