EXHIBIT 5.1


                   [DAVIS, MALM & D'AGOSTINE P.C. LETTERHEAD]


__________ __, 2005


Harbor Acquisition Corporation
One Boston Place
Boston, Massachusetts 02108

Ladies and Gentlemen:

       Reference is made to the Registration Statement on Form S-1 (the
"Registration Statement") filed by Harbor Acquisition Corporation (the
"Company"), a Delaware corporation, under the Securities Act of 1933, as amended
(the "Act"), covering (i) 10,000,000 Units, with each Unit consisting of one
share of the Company's common stock, par value $.0001 per share (the "Common
Stock"), and two warrants to each purchase one share of the Company's Common
Stock (the "Warrants") to the underwriters for whom Ferris, Baker Watts,
Incorporated is acting as the lead underwriter (the "Underwriter"), (ii) up to
1,500,000 Units (the "Over-Allotment Units") which the Underwriter will have a
right to purchase from the Company to cover over-allotments, if any, all shares
of Common Stock, (iii) all Warrants issued as part of the Units and the
Over-Allotment Units and (iv) all shares of Common Stock issuable upon exercise
of the Warrants included in the Units and the Over-Allotment Units.

       We have examined such documents and considered such legal matters as we
have deemed necessary and relevant as the basis for the opinion set forth below.
With respect to such examination, we have assumed the genuineness of all
signatures, the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as reproduced
or certified copies, and the authenticity of the originals of those latter
documents. As to questions of fact material to this opinion, we have, to the
extent deemed appropriate, relied upon certain representations of certain
officers and employees of the Company.

       Based upon the foregoing, we are of the opinion that:

       1. The Units, the Over-Allotment Units, the Warrants and the Common Stock
to be sold to the Underwriters, when issued and sold in accordance with and in
the manner described in the plan of distribution set forth in the Registration
Statement, will be duly authorized, validly issued, fully paid and
non-assessable.

       2. Each of the Warrants constitutes a legal, valid and binding obligation
of the Company, enforceable against it in accordance with its terms, except (i)
as limited by applicable bankruptcy, insolvency, reorganization, moratorium, and
other laws of general application affecting enforcement of creditors' rights
generally, (ii) as limited by laws relating to the availability of specific
performance, injunctive relief, or other equitable remedies, and (iii) to the
extent indemnification provisions contained such documents, if any, may be
limited by applicable federal or state law and considerations of public policy.

       We are opining solely on all applicable statutory provisions of Delaware
corporate law, including the rules and regulations underlying those provisions,
all applicable provisions of the Delaware Constitution and all applicable
judicial and regulatory determinations. We hereby consent to the use of this
opinion as an exhibit to the Registration Statement, to the use of our name as
your counsel and to all references made to us in the Registration





Harbor Acquisition Corporation
__________ __, 2005
Page 2


Statement and the Prospectus forming a part thereof. In giving this consent, we
do not hereby admit that we are in the category of persons whose consent is
required under Section 7 of the Act, or the rules and regulations promulgated
thereunder.

                                         Very truly yours,

                                         DAVIS, MALM & D'AGOSTINE, P.C.


                                         By:
                                            ------------------------------------
                                                       Managing Director