Attached files

                                    EXHIBIT 5





                               HART & TRINEN, LLP
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________           Email:  harttrinen@aol.com
Donald T. Trinen                                      Facsimile:  (303) 839-5414
                                  (303) 839-0061
--

Will Hart
                                 August 3, 2011

DNA Brands, Inc.
506 NW 77th Street
Boca Raton, Florida, 33487

     This letter will  constitute  an opinion  upon the  legality of the sale by
certain   shareholders  of  DNA  Brands,   Inc.,  a  Colorado  corporation  (the
"Company"),  of up to  4,427,000  shares of common  stock as  referred to in the
Registration  Statement on Form S-1 filed by the Company with the Securities and
Exchange Commission.

     We have examined the Articles of Incorporation, the Bylaws, and the minutes
of the Board of Directors of the Company,  the  applicable  laws of the State of
Colorado, and a copy of the Registration  Statement. In our opinion, the Company
was  authorized to issue the shares to be sold by the selling  shareholders  and
such shares are legally issued, fully paid and non-assessable.

                                           Very truly yours,

                                           HART & TRINEN

                                           /s/ William T. Hart

                                           William T. Hart