EXHIBIT 5.1 Patton Boggs LLP 1660 Lincoln Street Suite 1900 Denver, Colorado 80264 (303) 830-1776 June 12, 2000 COL China Online International Inc. 3177 South Parker Road Aurora, Colorado 80014 Gentlemen and Ladies: We have acted as counsel for COL China Online International Inc., a Delaware corporation (the "Company"), in connection with preparation of the Company's Registration Statement on Form SB-2 (the "Registration Statement") under the Securities Act of 1933, as amended, concerning registration of the transfer of a minimum of 1,500,000 and up to a maximum of 2,000,000 shares of the Company's $.001 par value common stock (the "Common Stock") to be issued by the Company and registration of the transfer of 1,250,000 shares of Common Stock presently issued and outstanding to be sold by certain selling stockholders. We have examined the Certificate Of Incorporation, as amended, and the Bylaws of the Company and the record of the Company's corporate proceedings concerning the registration described above. In addition, we have examined such other certificates, agreements, documents and papers, and we have made such other inquiries and investigations of law as we have deemed appropriate and necessary in order to express the opinion set forth in this letter. In our examinations, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, photostatic, or conformed copies and the authenticity of the originals of all such latter documents. In addition, as to certain matters we have relied upon certificates and advice from various state authorities and public officials, and we have assumed the accuracy of the material and the factual matters contained herein. Subject to the foregoing and on the basis of the aforementioned examinations and investigations, it is our opinion that the shares of Common Stock will have been legally issued and will constitute fully paid and non-assessable shares of the Company's Common Stock. We hereby consent (a) to be named in the Registration Statement and in the prospectus that constitutes a part of the Registration Statement as acting as counsel in connection with the offering, including with respect to the issuance of securities offered in the offering; and (b) to the filing of this opinion as an exhibit to the Registration Statement. This opinion is to be used solely for the purpose of the registration of the Common Stock and may not be used for any other purpose. Very truly yours, /s/ Patton Boggs LLP PATTON BOGGS LLP