Exhibit 5.1                   Opinion re: legality

                  [Letterhead of Argento & Associates Law Firm


                                  Oct 1, 2007

Edward Alexander, Chief Executive Officer
PROTON LABORATORIES, INC.
980 Atlantic Avenue, Suite 110
Alameda, CA 94501

Dear Mr. Alexander:

          As counsel for PROTON LABORATORIES, INC., a State of Washington
corporation(the "Company"), you have requested me to render this opinion in
connection with the Registration Statement of the Company on Form SB-2
("Registration Statement") under the Securities Act of 1933, as amended (the
"Securities Act"),filed with the Securities and Exchange Commission relating to
the resale of 7,750,000 shares of common stock, par value $.0001 per share (the
"Common Stock") by certain security holders of the Company who are listed as the
Selling Stockholders in the Registration Statement. Of these shares, 4,250,000
are issued and outstanding, and 3,500,000 are authorized and reserved for
issuance pursuant to a conversion right of a debtholder.

          I am familiar with the Registration Statement and the registration
contemplated thereby. In giving this opinion, I have reviewed the Registration
Statement and such other documents and certificates of public officials and of
officers and directors of the Company with respect to the accuracy of the
factual matters contained therein as I have felt necessary or appropriate in
order to render the opinions expressed herein. In making my examination, I have
assumed the genuineness of all signatures, the authenticity of all documents
presented to us as originals, the conformity to original documents of all
documents presented to us as copies thereof, and the authenticity of the
original documents from which any such copies were made, which assumptions I
have not independently verified.

          Based upon the foregoing, I am of the opinion that:

1.             The Company is a corporation duly organized, validly existing and
               in good standing under the laws of the State of Washington.

2.             4,250,000  shares  of  Common Stock are validly issued, fully
               paid and nonassessable.

3.             3,500,000  shares  of  common  stock  are  validly authorized and
               are  reserved  for  issuance  per  the  conversion  right  of  a
               debtholder.


          I consent to the use in the Registration Statement of the reference to
Argento & Associates Law Firm as an expert under the heading " INTEREST OF NAMED
EXPERTS AND COUNSEL."

          This opinion is conditioned upon the Registration Statement being
declared effective by the Securities and Exchange Commission and upon compliance
by the Company with all applicable provisions of the Securities Act and such
state securities rules, regulations and laws as may be applicable.

                                Very truly yours,


                           /s/ Paula A. Argento, Esq.