Exhibit 5.1

Shutts & Bowen LLP

200 South Biscayne Boulevard
Suite 4100
Miami, FL 33131

DIRECT (305) 358-6300

FAX (305) 3581-9982

July 27, 2023

InnovaQor, Inc.

400 South Australian Avenue

Suite 800

West Palm Beach, Florida 33401

Ladies and Gentlemen:

We have acted as counsel to InnovaQor, Inc., a Nevada corporation (the “Company”), in connection with the preparation and filing with the Securities and Exchange Commission (the “Commission”) of a Registration Statement on Form S-1, Registration No. 333 - 273288 (such registration statement, as amended, is referred to as the “Registration Statement”), covering the offering for resale, on a delayed or continuous basis, of 81,651,000 shares of the Company’s common stock, par value $0.0001 per share (the “Common Stock”), to be sold by the selling stockholder named in the Registration Statement (the “Selling Stockholder”), issuable upon conversion of shares of Series B-1 Convertible Redeemable Preferred Stock, par value $0.0001 per share (the “Series B-1 Preferred Stock” and such shares of Common Stock that may be issued upon conversion thereof, the “Conversion Shares”).

The shares of Series B-1 Preferred Stock were issued in connection with the Acquisition Agreement, dated as of May 12, 2021, between the Company and the Selling Stockholder, as supplemented on June 25, 2021 (the “Agreement”). This opinion is being rendered in connection with the filing of the Registration Statement. All capitalized terms used herein and not otherwise defined shall have the respective meanings given to them in the Registration Statement.

In connection with this opinion, we have examined originals or copies, certified or otherwise identified to our satisfaction, of (i) the Registration Statement as filed with the Commission on July 17, 2023, under the Securities Act of 1933, as amended (the “Securities Act”); (ii) the Registration Statement as filed with the Commission on July 27, 2023, under the Securities Act; (iii) the Articles of Incorporation of the Company, as amended, as currently in effect; (iv) the By-Laws of the Company, as amended, as currently in effect; and (v) certain resolutions and minutes of meetings of the Board of Directors of the Company relating to the Registration Statement, the Series B-1 Preferred Stock, the Agreement and the transactions contemplated thereby. We have also examined originals or copies, certified or otherwise identified to our satisfaction, of such records of the Company and such agreements, certificates of public officials, certificates of officers or other representatives of the Company and others, and such other documents, certificates and records as we have deemed necessary or appropriate as a basis for the opinion set forth herein.

In our examination, we have assumed the legal capacity of all natural persons, the genuineness of all signatures, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as facsimile, electronic, certified, conformed or photostatic copies, and the authenticity of the originals of such copies. In making our examination of executed documents, we have assumed that the parties thereto, other than the Company, had the power, corporate or other, to enter into and perform all obligations thereunder and have also assumed the due authorization by all requisite action, corporate or other, and the execution and delivery by such parties of such documents and the validity and binding effect thereof on such parties. As to any facts material to the opinion expressed herein which we have not independently established or verified, we have relied upon statements and representations of officers and other representatives of the Company and others.

InnovaQor, Inc.

July 27, 2023

Page 2

Based upon the foregoing and subject to the limitations set forth below, we are of the opinion that the Conversion Shares issuable upon conversion of the Series B-1 Preferred Stock have been duly authorized and when issued upon conversion of the Series B-1 Preferred Stock pursuant to the terms thereof, will be validly issued, fully paid and non-assessable.

We express no opinion as to matters governed by laws of any jurisdiction other than the laws of the State of Nevada and the federal laws of the United States of America, as in effect on the date hereof.

We are opining only as to matters expressly set forth herein, and no opinion should be inferred as to any other matters. This opinion is rendered as of the date hereof and is based upon currently existing statutes, rules, regulations and judicial decisions. We disclaim any obligation to advise you of any change in any of these sources of law or subsequent legal or factual developments that affect any matters or opinions set forth herein.

This opinion is furnished in connection with the filing of the Registration Statement and may not be relied upon for any other purpose without our prior written consent in each instance. Further, no portion of this letter may be quoted, circulated or referred to in any other document for any other purpose without our prior written consent.

We understand that you wish to file this opinion as an exhibit to the Registration Statement, and we hereby consent thereto. We hereby further consent to the reference to us under the caption “Interests of Named Experts and Counsel” in the prospectus included in the Registration Statement and in any Rule 462(b) registration statement. In giving such consent, we do not hereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission.

Very truly yours,

/s/ Shutts & Bowen LLP

InnovaQor, Inc. S-1/A