(a) all Documents submitted to us as copies conform to their originals and all Documents submitted to us as originals are authentic; (b) all signatures, seals and chops on such Documents are genuine; and (c) other than Jinjiang Company, all parties have the requisite power and authority to enter into, and have duly executed and delivered under the laws other than those of the PRC, the Documents; (d) all facts and information stated or given in such Documents are true, correct and complete; (e) all persons who purport to act for and on behalf of the Group Companies have sufficient legal capacity to enter into and perform the transactions contemplated by the Documents or to carry out their respective roles in such transactions; (f) each of the Documents has been duly authorized, executed, and delivered by the parties other than Jinjiang Company; and (g) in response to our due diligence inquiries, requests and investigations for the purpose of this opinion, all the information and materials provided to us by the Group Companies are true, accurate, complete and not misleading, and that the Group Companies have not withheld anything that, if disclosed to us, would reasonably cause us to alter this opinion in whole or in part.

The Documents that were presented to us remain in full force and effect on the date of this opinion and have not been revoked, cancelled, amended, superseded or supplemented, and no amendments, revisions, supplements, modifications or other changes have been made, and no revocation or termination has occurred, with respect to any of the Documents after they were submitted to us for the purposes of this legal opinion;

All the explanations and interpretations provided by the government officers, which duly reflect the official position of the relevant Government Agencies, and all the Documents and the factual statements provided to us by the Group Companies, including but not limited to those set forth in the Documents, are complete, true, correct and not misleading. Where important facts were not independently established to us, we have relied upon certificates issued by the Government Agencies with proper authority which are available to us; and

The applicable PRC statute, judgment, order or decree, rule, regulation and facts shall remain unchanged as of the date hereof and will not be changed.

We have further assumed, with your consent, that (a) each of 8888 Acquisition Corporation (the “Shell Company”) and the Company is duly incorporated, duly organized, validly existing and in good standing under the laws of the jurisdiction of their establishment, and have the corporate power to execute, deliver and fully perform its obligations under the Transaction Documents, and have taken all necessary corporate action to authorize the execution, delivery and performance by them of the Transaction Documents; (b) the Share Exchange Agreement has been entered into between the Shell Company and the Company, and has binding force on each party upon execution according to the governing law of the Share Exchange Agreement;.

“Government Agencies” mean any competent government authorities, courts or regulatory bodies of the PRC;

“Governmental Authorizations” mean all approvals, consents, permits, authorizations, filings, registrations, exemptions, waivers, endorsements, annual inspections, qualifications and licenses required by the applicable PRC Laws to be obtained from the competent Government Agencies;

“PRC Laws” mean all laws and regulations currently in force and publicly available in the PRC as of the date hereof;

Our opinion is limited to the PRC Laws of general application effective as of the date hereof. We have made no investigation of, and do not express or imply any views on, the laws of any country other than the PRC;

This opinion is intended to be used in the context which is specifically referred to herein;

The PRC Laws referred to herein are laws and regulations publicly available and currently in force on the date hereof and there is no guarantee that any of such laws and regulations or the interpretation or enforcement thereof, will not be changed, amended or revoked in the immediate future or in the long term with or without retrospective effect;

This opinion is issued based on our understanding of the current PRC Laws. For matters not explicitly provided under the current PRC Laws, the interpretation, implementation and application of the specific requirements under the PRC Laws are subject to the final discretion of competent PRC legislative, administrative and judicial authorities, which may be different from our opinion; and

We may rely, as to matters of fact (but not as to legal conclusions), to the extent reasonable, on certificates and confirmations of Government Agencies or responsible officers of the Company and Jinjiang Company.

Share Exchange Agreement, dated October 19, 2010, by and among the Shell Company, the Company and shareholders of the Company

Securities Purchase Agreement, dated October 19, 2010, by and among the Shell Company and investors signatories thereto

Make Good Escrow Agreement, dated October 19, 2010, by and among the Shell Company, Guoqing Zhuang and Securities Transfer Corporation

Side Letter, dated October 19, 2010, by and among the Shell Company, Guoqing Zhuang, River Tyne Ventures Inc., Zhao Kang Capital Resource Limited and transferees signatory thereto