Registration Statement draft provided to us on December 22, 2022, with the 2022 Restricted Stock Awards Plan attached as an exhibit; and

the certificate issued by the Company to us dated December 28, 2022.

the genuineness of all signatures on documents, the authenticity and completeness of all documents submitted to us as originals, the conformity to originals and completeness of all documents submitted to us as copies, the legal capacity of all persons or entities executing the same, the completeness and accuracy of translations of relevant documents, that all abstracted copies of relevant documents have duly included and provided all material terms and conditions of the original documents, the lack of any undisclosed termination, modification, waiver or amendment to any such document and the due authorization, execution and delivery of all such documents where due authorization, execution and delivery are prerequisites to the effectiveness thereof.

all public information, records and announcements which we have examined are accurate and that the information disclosed by the database and search systems of the relevant authorities is true and complete and that such information has not since then altered and that such searches did not fail to disclose any information which has been delivered for registration or publicity but did not appear on the public records as at the search date. Furthermore, all assumptions, limitations and qualifications contained in the databases and search systems we conducted our searches thereon are completely incorporated and applied to this opinion.

the meetings to resolve the Resolutions have been lawfully and duly convened and the Resolutions have been lawfully and duly approved and adopted thereby.

the accuracy and completeness of all factual matters reflected in such documents.

The Company has been duly incorporated and is validly existing as a company limited by shares under the laws of the ROC.

The New Shares have been duly authorized and, when delivered to the persons who have been granted with such New Shares under the 2022 Restricted Stock Awards Plan, will be validly issued, fully paid and non-assessable. For the purposes of this opinion, the term “non-assessable” in relation to shares of capital stock of the Company under the laws of the ROC means that no calls for further payment can be made upon such capital stock or upon any holders of such capital stock solely by reason of their ownership thereof.

Enforcement of rights for claims in relation to the subscription rights under the 2022 Restricted Stock Awards Plan and Resolutions is subject to applicable statutes of limitations under the laws of the ROC.

The courts of the ROC are free to look behind stipulations of fact contained in the transaction documents and independently determine such facts.

Under the ROC Code of Civil Procedures and under the ROC Code of Administrative Procedures, a party to the litigation has the right to dispute at the oral proceeding the fact alleged by the opposing party, and courts in the ROC have the discretionary power to admit or rule out evidence. Any determination, certificate or other matters stated in the transaction documents to be conclusive may nevertheless be subject to review by court.

The exercise of any right may not be repugnant to public interests or have a primary purpose to harm another person, and such right must be exercised in good faith.

No liability arising from willful misconduct or gross negligence may be disclaimed in advance.

We express no view or opinion on the ROC tax consequences in relation to the subscription rights under the 2022 Restricted Stock Awards Plan and New Shares.