[SPECTRUM LAW GROUP LETTERHEAD]





File No.:
                                                                     Exhibit 5.1

                                  June 8, 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
June 8, 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 No. 2 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