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                                                                EXHIBIT 5.1

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

__________ __, 2006

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, (iii) the
Underwriter's option to purchase (the "Underwriter's Purchase Option") up
to 500,000 units (the "Underwriter's Units"); (iv) all shares of Common
Stock constituting a part of the Units, the Over-Allotment Units and the
Underwriter's Units; (v) all Warrants issued as part of the Units , the
Over-Allotment Units and the Underwriter's Units; and (vi) all shares of
Common Stock issuable upon exercise of the Warrants included in the Units,
the Over-Allotment Units and the Underwriter's 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 Purchase Option, the
Underwriter's Units, the Warrants, and the Common Stock, 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

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Harbor Acquisition Corporation
_________ __, 2006
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