Converted by EDGARwiz

Securus Law Group, P.A.

13046 Racetrack Road, Number 243

Tampa, FL 33626

July 6, 2018

SW Innovative Holdings, Inc.

6666 Harwin

Suite 664

Houston, TX 77036

Re: Opinion as to Company Offering Statement on Form 1-A/A for SW Innovative Holdings,

Inc., SEC File Number 024-10801

Gentlemen:

We are acting as outside counsel to SW Innovative Holdings, Inc. (the “Company”) in

connection with the preparation and filing with the Securities and Exchange Commission, under

the Securities Act of 1933, as amended, of the Company’s Offering Statement on Form 1-A/A

under offering file number 024-10801. The Offering Statement covers 500,000,000 shares of the

Company’s common stock (the “Shares”).

In our capacity as outside counsel, we have examined and relied upon the originals or copies

certified or otherwise identified to our satisfaction, of the Offering Statement, the form of

Subscription Agreement and such corporate records, documents, certificates and other

agreements and instruments as we have deemed necessary or appropriate to enable us to render

the opinions hereinafter expressed.

On the basis of such examination, we are of the opinion that:

1. The Shares have been duly authorized by all necessary corporate action of the Company.

2. When issued and sold by the Company against payment therefor pursuant to the terms of the

Subscription Agreement, the Shares will be validly issued, fully paid and non-assessable.

We hereby consent to the use of our name in the Offering Statement and we also consent to the

filing of this opinion as an exhibit thereto. In giving 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 yours,

/s/ Craig A. Huffman

Craig A. Huffman, Esq.

Securus Law Group, P.A.