EXHIBIT 5.1

                              MINTMIRE & ASSOCIATES
                                ATTORNEYS AT LAW

                                                   265 Sunrise Avenue, Suite 204
                                                       Palm Beach, Florida 33480
                                                                  (561) 832-5696


January 17, 2002

Board of Directors
L.L. Brown International, Inc.
19435 68th Avenue South, Suite S-105
Kent, Washington 98032

Gentlemen:

At your request,  we have examined the Registration  Statement on Form S-8 to be
filed by you with the Securities and Exchange Commission on or about January 17,
2002, in connection with the  registration  under the Securities Act of 1933, as
amended,  of 1,000,000 shares of the Company's common stock, $0.001 par value to
be sold by you pursuant to the  Company's  Year 2002  Employee/Consultant  Stock
Compensation Plan. (the "Purchase Plan").

As your counsel,  we have examined the proceedings  relating to and action taken
by you in connection with the adoption of the Purchase Plan.

It is our opinion that the 1,000,000  shares of the Stock that may be issued and
sold by the  Company  pursuant  to the Plan,  when issued and sold in the manner
provide in the Plan, will be validly issued, fully-paid and non-assessable.

We  consent  to the  use of  this  opinion  as an  exhibit  to the  Registration
Statement  and  further  consent  to all  references  to us in the  Registration
Statement and any  amendments  thereto.  In providing  this  consent,  we do not
thereby  admit that we are  within the  category  of  persons  whose  consent is
required  under  Section  7 of the  Securities  Act of 1933,  or the  rules  and
regulations of the Commission thereunder.



                            Very truly,

                            /s/ Mintmire & Associates
                             Mintmire & Associates