GARY R. BLUME, P.C.
                              A PROFESSIONAL CORPORATION

                                    Attorneys At Law
                         11801 North Tatum Boulevard, Suite 108
                              Phoenix, Arizona  85028-1612

                                Telephone (602) 494-7976
                                Facsimile (602) 494-7313
                                Email gblume@getnet.com
           Gary R. Blume*                                 Steven M. Brechner
           * Licensed in Arizona and Minnesota


                                                October 10, 1997

To:       Subscribers of Series A Preferred Stock of Medcare Technologies, Inc.,
          a Delaware corporation (the "Company") in connection with the issuance
          of  1,000 shares of Series A Preferred Stock, par value $0.25 per 
          share of the Company 

Ladies and Gentlemen:

     We have acted as counsel to Medcare Technologies, Inc., a Delaware 
corporation (the "Company") in connection with the issuance of 1,000 shares of 
Series A Preferred Stock, par value $0.25 per share of the Company (the 
"Shares") in reliance on Rule 506 of the Securities Act of 1933 (the "Act") and 
the acceptance of certain Subscription Agreements dated June 20, 1997 by and
between the Company and the Subscriber, executed between June 16 and June 18 of 
1997.  This opinion is being delivered to you pursuant to Section 5.8 of the 
Subscription Agreements and Section 10.7 of the Placement Agent Agreement dated 
June 20, 1997 between the Company and Swartz Investments, L.L.C. (the "Placement
Agent").  Capitalized terms used herein without definition have the respective 
meanings assigned to them in the Subscription Agreements. 

     In connection with and as the basis for this opinion, we have examined, 
originals or copies certified or otherwise identified to us, of certain 
documents, corporate records and other instruments, including the following:  

        (i) the Certificate of Incorporation of the Company, as amended, 
certified as of a recent date by an officer of the Company; 

        (ii) the by-laws of the company as in effect on June 23, 1997, as 
certified by an officer of the Company 

        (iii) the Certificate of Designation of Series A Preferred Stock in the 
form submitted for filing with the Secretary of State of the State of Delaware; 

        (iv) a certificate dated June 30, 1997 by the Secretary of State of the 
State of Delaware regarding the existence and good standing of the Company as a 
corporation under the laws of the State of Delaware; 

<PAGE>
Subscriber of Shares
Swartz Investments, L.L.C.
July 8, 1997
Page 2

     Reference: Series A Preferred Stock of Medcare Technologies, Inc.


        (v) the minute books of the Company, including copies, certified to our 
satisfaction, of resolutions adopted by the Board of Directors of the Company on
June 30, 1997 and by the unanimous written consent of the Board of Directors of 
the Company executed on June 30, 1997; 

        (vi) various Subscription Agreements;

        (vii) the Registration Rights Agreement by and among the Company, the 
Placement Agent and the Subscribers (the "Registration Rights Agreement"); 

        (viii) the Escrow Agreement and Instructions by and among the Company, 
the Placement Agent, and First Union National Bank of Georgia (the "Escrow 
Agreement");  

        (ix) the Placement Agent Agreement; 

        (x) the Irrevocable Instructions to Transfer Agent, by and among the 
Company, the Company's transfer agent and the Subscribers (the "Irrevocable 
Instructions to Transfer Agent");  

        (xi) certain warrants to purchase the Company's common stock, par value 
$0.001 per share (the "Common Stock"), issued to Subscribers (the "Subscribers 
Warrants"); 

        (xii) certain warrants to purchase Series A Preferred Stock of the 
Company issued to Subscribers (the "Preferred Warrants"); and 

        (xiii) certain warrants to purchase the Company's Common Stock issued to
certain designees of the Placement Agent (the "Swartz Warrant Holders") in 
accordance with the Placement Agent Agreement (the "Swartz Warrants") (the 
Subscribers' Warrants, the Preferred Warrants and the Swartz Warrants are 
sometimes hereinafter collectively referred to as "Warrants").

We have also examined such other documents, records, certificates and questions 
of law as we have considered necessary or appropriate for the purpose of this 
opinion.

<PAGE>
Subscriber of Shares
Swartz Investments, L.L.C.
July 8, 1997
Page 3

     Reference: Series A Preferred Stock of Medcare Technologies, Inc.


     We have also examined, relied upon and assumed the accuracy, where 
appropriate, of the representations and warranties of the Company and other 
parties thereto contained in the Subscription Agreements as to the matters of 
fact therein represented.  As to certain questions of fact material to the 
opinions contained herein, we have, when appropriate, relied upon certificates
of statements of public officials and officers and agents of the Company and 
we have assumed that any certificates or statements of public officials dated 
earlier than the date of this letter are accurate on the date of this letter as 
if made on and as of such date.

     In our examination of documents described above, we have assumed the 
genuineness of all signatures, the authenticity of all documents submitted to us
as originals and the conformity to authentic originals of all documents 
submitted to us as copies.

     In addition, we have assumed that the representations and warranties as to 
factual matters and acknowledgments made by each Subscriber in Sections 2 and 3 
of the Subscription  Agreements are true and correct.

     The opinions contained herein are limited to our interpretation of the laws
of the State of Delaware and the federal laws of the United States.  Members of 
this firm are licensed to practice law in the jurisdictions of Minnesota and 
Arizona.  We express no opinion as to the laws of any other state or 
jurisdiction of the United States or of any foreign jurisdiction except our 
interpretation as detailed above.

     Based upon and subject to the foregoing and the qualifications, limitation 
and assumptions set forth herein, it is our opinion that, as of the date hereof:

     1. The Company is a corporation duly incorporated and validly existing 
under the laws of the State of Delaware.

     2. The Subscription Agreements, the issuance of the Preferred Stock, the 
issuance of the Common Stock upon conversion of the Preferred Stock, the 
issuance of the Preferred Warrants, the issuance of the Preferred Stock upon 
exercise of the Preferred Warrants, the issuance of the Subscribers' Warrants, 
the issuance of the Common Stock upon exercise of the Subscribers' Warrants, the
issuance of the Swartz Warrants, and the issuance of the Common Stock upon 
exercise of the Swartz Warrants, have been duly approved by all required 
corporate action on the part of the Company.

<PAGE>
Subscriber of Shares
Swartz Investments, L.L.C.
July 8, 1997
Page 4

     Reference: Series A Preferred Stock of Medcare Technologies, Inc.


     3.  The shares of Preferred Stock issued to the Subscribers are validly 
issued, fully paid and non assessable.

     4.  The Common Stock, when duly issued upon conversion and cancellation of 
the Preferred Stock in accordance with the Certificate of Incorporation and
Certificate of Designation, as then in effect, and in compliance with the 
provisions of the Subscription Agreements, will be validly issued, fully paid 
and non assessable. 

     5. The Common Stock, when duly issued upon exercise of the Subscribers' 
Warrants and Swartz Warrants, will be validly issued, fully paid and non 
assessable. 

     6. The Preferred Stock, when duly issued upon exercise of the Preferred 
Warrants, will be validly issued, fully paid and non assessable.

     7. The Subscription Agreements, the Registration Rights Agreement, the 
Irrevocable Instructions to Transfer Agent, the Placement Agent Agreement, the 
Escrow Agreement and the Warrants (the "Transaction Agreements") are valid and 
binding obligations of the Company, enforceable in accordance with their 
respective terms, except as enforceability of the indemnification provisions may
be limited by principles of public policy, and subject to laws of general 
application relating to bankruptcy, insolvency and the relief of debtors and 
rule of laws governing specific performance and other equitable remedies.

     8. Based, in part, upon the representations, warranties and acknowledgments
of the Subscribers contained in Sections 2 and 3 of the Subscription Agreement, 
the Preferred Stock and the Warrants have been, and the Common Stock issuable 
upon conversion of the Preferred Stock and upon exercise of the Subscribers' 
Warrants and the Swartz Warrants, and the Preferred Stock issuable upon exercise
of the Preferred Warrants, will be, issued in transactions that are exempt from 
the registration requirements of the Act, as amended, and applicable state 
securities laws, assuming the filing of all Securities and Exchange Commission 
and State Blue Sky documents subsequent to the writing of this opinion and that 
the Company comply with the continuing requirements of the Act. 

     9. The shares of Common Stock issuable on conversion of the Preferred Stock
and exercise of the Subscribers' Warrants and the Swartz Warrants are authorized
for quotation on  

<PAGE>
Subscriber of Shares
Swartz Investments, L.L.C.
July 8, 1997
Page 5

     Reference: Series A Preferred Stock of Medcare Technologies, Inc.


the OTC Bulletin Board, subject to notice of issuance.  This assumes the 
requirements of Rule 144 and or the registration of the Common Stock is complete
as required under and in conformity with the Act.

     10. For purposes of Rule 144 and sub section (d)(3)(ii) thereof, the Common
Stock issuable upon exercise of the Subscribers' Warrants and Swartz Warrants in
a cashless exercise transaction shall be deemed to have been acquired at the 
time the warrants were issued.  Moreover, the holding period for the Common 
Stock issuable upon exercise of the warrants in a cashless exercise transactions
shall be deemed to have commenced on the date such warrants were issued.

     11. The offering, sale and conversions of the Series A Preferred Stock will
not result in either (i) integration with any prior offering or placement of 
securities of the Company or (ii) a violation of NASDAQ Rule 4460(i)(1)(d)(ii) 
(the "NASDAQ 20% Rule").  

     The opinions set forth herein are subject to the following qualifications, 
limitations and assumptions:

     (A) We have assumed:

          (i) that the Transaction Agreements constitute the legal, valid and 
     binding obligations of the parties thereto other than the Company, 
     enforceable in accordance with their respective terms,

          (ii) that the parties to the Transaction Agreements other than the 
     company have the requisite corporate power and authority to enter into 
     such agreement and to perform their respective obligations thereunder and  

          (iii) that each of the parties to the Transaction Agreements other 
     than the Company has duly authorized, executed and delivered the 
     Transaction Agreements.  

We have also assumed the legal capacity of all natural persons whose acts are 
relevant to the opinion rendered herein.

     (B) We express no opinion and assume no responsibility as to the effect or,
or  

<PAGE>
Subscriber of Shares
Swartz Investments, L.L.C.
July 8, 1997
Page 6

     Reference: Series A Preferred Stock of Medcare Technologies, Inc.


consequences resulting from any legislative act or other change in law occurring
after the date of this letter.

     The foregoing opinion is intended solely for your benefit and is not to be 
made available to or be relied upon by any other persons, firm, or entity 
without our express prior written consent; provided, however, that the Swartz 
Warrant Holders may rely hereon as if this letter were addressed to such Swartz 
Warrant Holders.

                                                  Sincerely, 

                                                  GARY R. BLUME, P.C.


                                                  /s/ Gary R. Blume
                                                  Gary R. Blume
                                                  Attorney at Law


GRB/dlj