Legal Opinion of Guangdong Sundial Law Firm on the Issuance of Convertible Corporate Bonds to Non-Specific Targets by Shenzhen Qiangda Circuits Co., Ltd.

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Legal Opinion of Guangdong Sundial Law Firm on the Issuance of Convertible Corporate Bonds to Non-Specific Targets by Shenzhen Qiangda Circuits Co., Ltd.

11-12/F, Taiping Finance Tower, No. 6001 Yitian Road, Shenzhen, P. R. China

Tel: (0755) 8826 5288

Fax: (0755) 8826 5537

Website: www.sundiallawfirm.com

Table of Contents

Section 1: Lawyer's Statement

Section 2: Legal Opinion

1. Approval and Authorization of the Issuance

2. Subject Qualifications of the Issuer for the Issuance

3. Substantive Conditions for the Issuer's Issuance

4. Establishment of the Issuer

5. Independence of the Issuer

6. Promoters, Shareholders, and Actual Controllers

7. Changes in the Issuer's Share Capital

8. Business of the Issuer

9. Related Party Transactions and Competition

10. Major Assets of the Issuer

11. Major Creditor's Rights and Debts of the Issuer

12. Major Asset Changes and Mergers and Acquisitions of the Issuer

13. Formulation and Amendment of the Articles of Association

14. Standardized Operation of the Issuer's Shareholders' Meeting, Board of Directors, and Board of Supervisors

15. Directors, Supervisors, Senior Management, and Their Changes

16. Taxation of the Issuer

17. Environmental Protection, Production Safety, Product Quality, Technology, and Labor Employment of the Issuer

18. Use of Proceeds

19. Litigation, Arbitration, and Administrative Penalties

20. Evaluation of Legal Risks in the Prospectus

21. Business Development Goals of the Issuer

22. Other Issues Deemed Necessary by Lawyers

Section 3: Overall Conclusion on the Issuance

Definitions

In this document, unless the context otherwise requires, the following abbreviations have the following meanings: