March 3, 1998



Securities and Exchange Commission,
Division of Corporate Finance
450 Fifth Street, N.W., Judicial Plaza
Washington, D.C.  20549

Re:  Biomune Systems, Inc. Form S-8 Registration Statement Relating
     to 1,814,096 Shares of Common Stock

Ladies and Gentlemen:

     We have acted as counsel for Biomune Systems, Inc., a Nevada corporation 
(the "Company"), in connection with its proposed registration of a total of 
1,814,096 post-split shares of Common Stock, $0.0001 par value per share.  In 
that connection, it is our opinion that the securities being registered will, 
upon receipt by the Company of consideration for the securities and the 
issuance of the securities, be legally issued, fully-paid and non-assessable.

     We consent to the inclusion of our opinion as an Exhibit to the 
Registration Statement of Biomune Systems, Inc. on Form S-8 under the 
Securities Act of 1933, as amended.  We express no opinion on the law of any 
jurisdiction other than the Nevada Private Corporations Act, as amended, and 
the Securities Act of 1933, as amended.  

               Cordially,

               DURHAM, EVANS, JONES & PINEGAR
 
               /s/ Durham, Evans, Jones & Pinegar, P.C.