EXHIBIT 5.2 MINTMIRE & ASSOCIATES ATTORNEYS AT LAW 265 SUNRISE AVENUE SUITE 204 PALM BEACH, FLORIDA 33480 TEL: (561) 832-5696 FAX: (561) 659-5371 April 10, 2001 Board of Directors Itronics, Inc. 6490 S. McCarran Blvd., Bldg. C-23 Reno, NV 89509 Gentlemen: At your request, we have examined the Registration Statement on Form S-8 to be filed by you with the Securities and Exchange Commission on or about April 10, 2001, in connection with the registration under the Securities Act of 1933, as amended, of 2,000,000 shares of the Company's Common Stock, no par value (exclusive of any securities associated therewith, the "Stock") to be sold by you pursuant to the Company's Year 2001 Supplemental Employee/Consultant Stock Compensation Plan. (the "Purchase Plan"). As your counsel, we have examined the proceedings relating to and action taken by you in connection with the adoption of the Purchase Plan. It is our opinion that the 2,000,000 shares of the Stock that may be issued and sold by the Company pursuant to the Plan, when issued and sold in the manner provide in the Plan, will be validly issued, fully-paid and non-assessable. We consent to the use of this opinion as an exhibit to the Registration Statement and further consent to all references to us in the Registration Statement and any amendments thereto. In providing this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, or the rules and regulations of the Commission thereunder. Very truly yours, MINTMIRE & ASSOCIATES /s/ Donald F. Mintmire Donald F. Mintmire, Esq. DFM/mt