EXHIBIT 5.1

                       [SPECTRUM LAW GROUP LLP LETTERHEAD]


                                December 16, 2005

Amazon Biotech, Inc.
43 West 33rd Street, Suite 405
New York, New York 10001

      Re: Amazon Biotech, Inc./ Registration Statement on Form SB-2

Gentlemen:

      We are special counsel to Amazon Biotech, Inc., a Utah corporation (the
"Company"). In connection with the preparation and filing of a Form SB-2
Registration Statement with the Securities and Exchange Commission under the
Securities Act of 1933, as amended (the "Registration Statement"), relating to
the sale by certain selling stockholders (the "Selling Stockholders") of
5,090,000 shares of Common Stock, par value $0.001 per share (the "Common
Stock") of the Company, of which (i) 3,545,000 shares (the " Shares") are
currently outstanding and (ii) 1,545,000 shares (the "Warrant Shares") are
issuable upon the exercise of outstanding warrants (the "Warrants"), we have
examined the originals or copies of corporate records, certificates of public
officials and officers of the Company and other instruments relating to the
authorization and issuance of such shares of Common Stock as we have deemed
relevant and necessary for the opinion hereinafter expressed.

      On the basis of the foregoing, we are of the opinion (i) the Shares to be
offered and sold by the Selling Stockholders have been duly authorized, and are
legally issued, fully paid and non-assessable and (ii) the Warrant Shares to be
offered and sold by the Selling Stockholders have been duly authorized and, when
issued by the Company in accordance with the terms of the Warrants, will 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 further consent to the use of our name wherever
appearing in the Registration Statement, including the prospectuses constituting
a part thereof and any amendment thereto.


                             Sincerely,

                             SPECTRUM LAW GROUP LLP

                             /s/ Spectrum Law Group LLP