Austin Legal Group, APC

LAWYERS

3990 OLD TOWN AVE, STE A-101

SAN DIEGO, CA 92110

ATTORNEYS LICENSED IN CALIFORNIA & HAWAII

TELEPHONE

(619) 924-9600

FACSIMILE

(619) 881-0045

Writer's Email:

April 25, 2022

OTC Markets Group, Inc.

300 Vesey Street, 12th Floor

New York, NY 10282

Re:Attorney Letter with Respect to Adequate Current Information for ECom Products Group Corporation for fiscal year ended December 31, 2021.

Austin Legal Group, APC (this "firm") has been retained by ECom Products Group Corporation, a Florida corporation with its principal executive office in St. Petersburg, Florida (the "Issuer"), for the purpose of rendering this letter and related matters. This firm serves as special counsel to the Issuer. Neither this firm nor any attorney in this firm owns any shares of the Issuer's securities and there is no agreement to receive shares of the Issuer for this firm's services.

OTC Markets Group is entitled to rely on this letter in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) under the Securities Act of 1933 for fiscal year ended December 31, 2021.

I am a U.S. resident and licensed to practice law in California. The jurisdictions covered by this letter include the laws of the United States of America. I am permitted to practice before the Securities and Exchange Commission (the "SEC") and have not, at any time, been prohibited from practice thereunder. I am not currently the subject of an investigation, hearing, or proceeding by the SEC, the U.S Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory Authority (FINRA), or any other federal, state, or foreign regulatory agency, nor have been at any time in the past five years. I am not and have not been at any time in the past five years, suspended or barred from practicing in any state or jurisdiction, nor have been charged in a civil or criminal case.

This firm has examined such corporate records and other documents, and such questions of law, as this firm has considered necessary or appropriate for purposes of rendering this letter. The documents that this firm has reviewed (the "Information") include, but are not limited to:

a.

The Issuer's "Annual Report - Amended Annual Report Y/E 2020 (unaudited)" for the fiscal year ended December 31, 2020, filed April 25, 2022; and

b. The Issuer's "Annual Report - Amended Annual Report Y/E 2021 (unaudited)" for the fiscal year ended December 31, 2021, filed April 25, 2022.

As to matters of fact, this firm has relied on information obtained from public officials, officers and directors of the Issuer and other sources, and these sources are believed to be reliable. In examining the Information, this firm has assumed that:

  • 1. All statements and representations contained therein were accurate and reliable;

  • 2. All signatures contained therein were genuine;

  • 3. All documents submitted to me were true and accurate copies; and

  • 4. All natural persons who signed documents had the legal capacity to do so.

Based on the foregoing review and other matters set forth herein, it is this firm's opinion that the Information (i) constitutes "adequate current public information" concerning the Securities and the Issuer and "is available" within the meaning of Rule 144(c)(2) under the Securities Act, (ii) includes all of the information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the Securities under Rule 15c2-11 under the Securities Exchange Act of 1934 (the "Exchange Act"), (iii) complies as to form with the OTC Markets Group's Pink Disclosure Guidelines, which are located on the Internet atwww.otcmarkets.com,and (iv) has been posted through the OTC Disclosure & News Service.

This opinion speaks only to the periods and the matters addressed above and no opinion is rendered as to the veracity or accuracy of the information presented in the Information. Readers should not presume that the status of the Issuer as reported in its last disclosure is the current status of the Issuer or that there have not been material changes to the Issuer's management, capital structure or business plans since its last disclosure. The opinions set forth herein are expressed as of the date hereof and remain valid so long as the documents, instruments, records, and certificates this firm has examined and relied upon as noted above are unchanged and the assumptions this firm has made, as noted above, are valid. If any facts or documents are determined to be incorrect, misstated, or misrepresented, then the opinions expressed herein may not continue to be valid. Furthermore, this firm disclaims any undertaking to advise on developments hereafter occurring or coming to this firm's attention, whether or not the same would (if now existing and known to this firm) cause any change or modification herein.

The individual responsible for the preparation of the unaudited Consolidated Financial Statements contained in the Information was Ram Sivaraman. The Issuer has represented that Mr. Sivaraman's qualifications include having a Bachelor's Degree in Accounting, being a Chartered Accountant (CA), and having years of experience performing consulting and accounting services for manufacturing, wholesale, medical, hospitality and real estate companies.

The Issuer's transfer agent is ClearTrust, LLC ("CT"), which is registered with the SEC. This firm has relied upon information provided by CT to confirm the number of outstanding common shares set forth in the Information.

I have met through teleconference with Andrew Waters, the Executive Chairman, Chief Executive Officer, Chief Financial Officer, and Secretary of the Issuer, and Wing-Yun Wong, a director of the Issuer, with whom I discussed the Information after review. To the best of this firm's knowledge, after inquiry of the foregoing individuals, neither they, the Issuer of the securities, norcounsel, nor any beneficial owner of 5% or more of the Issuer's common stock is currently under investigation by any federal or state regulatory authority for any violation of federal or state securities laws.

The Issuer has represented that it has never been considered a "shell company" as defined in Rules 405 of the Securities Act of 1933 and 12b-2 of the Exchange Act. Furthermore, the Issuer has provided this firm with non-public documents indicating that the Issuer has maintained operations since its inception.

No person other than OTC Markets Group is entitled to rely on this letter; however, OTC Markets Group has full and complete permission to publish this letter in the OTC Disclosure & News Service for viewing by the public.

Sincerely,

AUSTIN LEGAL GROUP, APC

Gina Austin, Esq.

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ECom Products Group Corporation published this content on 25 April 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 25 April 2022 22:49:04 UTC.