EXHIBIT 5.0

                      Registration Statement Form SB-2

                                   EXHIBIT 5.0
                                 April 28, 2000

Silk Botanicals.Com, Inc.
975 South Congress Avenue, Suite 102
Delray Beach, FL  33450

Re: Registration Statement on Form SB-2

Ladies and Gentlemen:

         We are counsel for Silk Botanicals.Com, Inc., a Florida corporation
(the "Company") in connection with its proposed public offering under the
Securities Act of 1933, as amended, of up to 3,018,666 shares of its securities
through a Registration Statement on Form SB-2 ("Registration Statement") 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, and amendment thereto, of the Company as
filed with the Secretary of State of the State of Florida.

         (2) Corporate minutes containing the written deliberations and
resolutions of the Board of Directors and shareholders of the Company.

         (3) The Registration Statement and the Preliminary Prospectus contained
within the Registration Statement.

         (4) The other exhibits to the Registration Statement.

         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 Units, Common Stock, Warrants and Common Stock issuable upon exercise
of the Warrants offered under the Registration Statement will, upon the
purchase, receipt of full payment, issuance and delivery in accordance with the
terms of the offering described in the Registration Statement, be fully and
validly authorized, legally issued fully paid and non-assessable.



         We hereby consent to the use of this opinion, as an exhibit to the
Registration Statement and to the use of our name under the caption "Legal
Matters" in the Prospectus constituting a part thereof.

         Very truly yours,

         Hackney & Miller, P.A.