[LETTERHEAD]





                                       August 3, 1998               58640-0003

Jenkon International, Inc.
7600 N.E. 41st Street
Suite 350
Vancouver, Washington 98662

     Re:  Jenkon International, Inc. (the "Company") Registration
          Statement For Offering of Common Stock, $.001 Par
          Value ("Common Stock")

Gentlemen:

     At your request, we have examined the Registration Statement on Form 
SB-2, as amended, Registration No. 333-56023 (the "Registration Statement"), 
filed by the Company with the Securities and Exchange Commission in 
connection with the registration under the Securities Act of 1933, as 
amended (the "Act"), of (i) 1,210,000 shares of Common Stock for sale by the 
Company (the "Company Stock"), (ii) 290,000 shares of Common Stock for sale 
by certain selling stockholders (the "Selling Stockholder Stock"), (iii) up 
to 170,000 shares of Common Stock that may be sold by certain selling 
stockholders upon exercise of the underwriters' over-allotment option (the 
"Selling Stockholder Over-Allotment Stock"), and (iv) up to 55,000 shares of 
Common Stock that may be sold by the Company upon exercise of the 
underwriters' over-allotment option (the "Company Over-Allotment Stock"). We 
are familiar with the actions taken and proposed to be taken by the Company 
in connection with the authorization and proposed issuance and sale of the 
Company Stock. The Company Stock, the Company Over-Allotment Stock, the 
Selling Stockholder Stock and the Selling Stockholder Over-Allotment Stock 
are sometimes collectively referred to herein as the "Registered Stock."

     It is our opinion that when the Registration Statement has become 
effective under the Act, subject to said actions being duly taken and 
completed by you as now contemplated prior to the issuance of the Company 
Stock and the Company Over-Allotment Stock and subject to the appropriate 
qualification of the Registered Stock by the appropriate authorities of the 
various states in which the such Registered Stock will be sold, (i) the 
Company Stock and the Company Over-Allotment Stock will, upon the issuance 
and the sale thereof in the manner referred to in the Registration Statement, 
be legally issued, fully paid and non-assessable, (ii) the Selling 
Stockholder Stock and the Selling Stockholder Over-




Jenkon International, Inc.
August 3, 1998
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Allotment Stock will, upon the sale thereof in the manner referred to in the 
Registration Statement, be legally issued, fully-paid and non-assessable.

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

                                       Respectfully submitted,



                                  JEFFER, MANGELS, BUTLER & MARMARO LLP