FRANK J. HARITON, ATTORNEY AT LAW

 

1065 Dobbs Ferry Road, White Plains, New York 10607

TEL (914) 674-4373

FAX (914) 693-2963

 

June 2, 2020

 

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

 

Re: Haibo Sym, Inc. - Offering Statement on Form 1-A

 

Ladies and Gentlemen:

 

I have been requested by Haibo Sym, Inc., a Wyoming corporation (the "Company"), to furnish you with my opinion as to the matters hereinafter set forth in connection with the above-captioned offering statement (the "Offering Statement") covering an aggregate of 7,000,000 shares offered on behalf of the Company (the “Shares”).

 

In connection with this opinion, I have examined the Offering Statement and the Company's Certificate of Incorporation and By-laws (each as amended to date), copies of the records of corporate proceedings of the Company, and such other documents as I have deemed necessary to enable me to render the opinion hereinafter expressed.

 

Based upon and subject to the foregoing, I am of the opinion that the Shares will, upon issuance in accordance with the terms set forth in the Offering Statement, including the payment of the consideration therefor set forth therein, by fully paid, duly authorized, issued and outstanding shares of the Company’s common stock.

 

I render no opinion as to the laws of any jurisdiction other than the States of New York and Wyoming. I hereby consent to the use of this opinion as an exhibit to the Offering Statement and to the reference to my name under the caption "Legal Matters" in the Offering Statement and in the offering circular included in the Offering Statement. I confirm that, as of the date hereof, I own 50,000 shares of the common stock of the Company.

 

Very truly yours,

 

/s/ Frank J. Hariton

Frank J. Hariton,

Attorney-at- Law