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                                    Jody M. Walker
                                7841 South Garfield Way
                                 Littleton, Colorado 80122
                                 Telephone (303) 850-7637
                                 Facsimile (303) 220-9902

October 6, 1999

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

Dear Sirs:

Re:   OPINION RE: LEGALITY AND CONSENT OF COUNSEL TO USE OF NAME IN THE
REGISTRATION STATEMENT ON FORM SB-2 OF BIONET TECHNOLOGIES, INC.

I am securities counsel for the above mentioned Company and I have
prepared the amendment to the registration statement on Form SB-2.  I
hereby consent to the inclusion and reference to my name in the
Registration Statement on Form SB-2 for BioNet Technologies, Inc..

It is my opinion that the securities of BioNet Technologies, Inc. and
those which are registered with the Securities and Exchange Commission
pursuant to Form SB-2 Registration Statement of BioNet Technologies.
have been legally issued and will be, when sold, legally issued, fully
paid and non-assessable.


                                                Yours very truly,



                                                /s/   Jody M. Walker
                                               ---------------------
                                                Jody M. Walker