[SPECTRUM LAW GROUP LETTERHEAD]

File No.:
                                                                     Exhibit 5.1

                                 March 17, 2006

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

Ladies and Gentlemen:

         As special counsel for Amazon Biotech, Inc. (the "Company"), we have
examined its Certificate of Incorporation and Bylaws, as amended, and such other
corporate records, documents and proceedings, and such questions of law as we
have deemed relevant for the purpose of this opinion. We have also, as such
counsel, examined the registration statement of the Company on Form S-8 to be
filed by the Company with the Securities and Exchange Commission on or about
March 17, 2006 (the "Registration Statement") covering the registration under
the Securities Act of 1933, as amended, an aggregate of up to 4,000,000 shares
of common stock, $0.001 par value per share (the "Shares") to be issued pursuant
to the 2006 Stock Incentive Plan of the Company (the "Plan").

         Upon the basis of such examination, we are of the opinion that the
Shares will be, when issued and sold in the manner referred to in the Plans,
duly and validly issued as fully paid and non-assessable securities of the
Company.

         We wish to advise that members of this firm who have worked on the
Registration Statement and their affiliates may receive a portion of the Shares
to be issued pursuant to the Registration Statement.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement.


                                                     Very truly yours,

                                                     /s/ Spectrum Law Group, LLP