[SPECTRUM LAW GROUP LETTERHEAD]





File No.:
                                                                     Exhibit 5.1

                                November 22, 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
November 22, 2006 (the "Registration Statement") covering the registration under
the Securities Act of 1933, as amended,  an aggregate of up to 7,000,000  shares
of common stock, $0.001 par value per share (the "Shares") to be issued pursuant
to the 2006 Stock Incentive Plan No. 3 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