A. Defendant A Co., Ltd. (hereinafter “Defendant A Co., Ltd.”) is a company that has engaged in funeral ceremony business in the manner of providing prepaid installment transactions under Article 2 subparag. 4 of the Installment Transactions Act (hereinafter “Installment Transactions Act”), i.e., soliciting consumers and receiving advance payments, and supplying services, etc. for funerals, and Defendant B is a joint and several surety for the Plaintiff, as seen thereafter.

The plaintiff is a mutual aid association established pursuant to Article 28 of the Installment Transactions Act.

B. On February 27, 2013, the Plaintiff entered into a mutual aid agreement and a joint and several sureties agreement with the Defendant Company, setting the credit limit of 9,592,286,600 won, and the period from March 18, 2013 to March 17, 2014 during the mutual aid transaction agreement. The Defendant Company paid the mutual aid fee to the Plaintiff, and the Plaintiff entered into a mutual aid agreement with the Defendant Company to pay the mutual aid fee to the Defendant Company’s consumers (hereinafter “instant mutual aid agreement”).

In addition, until March 17, 2014, Defendant Company paid KRW 880,000,000 and KRW 1,024,540,531 to the Plaintiff.

The content of the instant mutual aid agreement and the mutual aid provisions attached thereto [mutual aid agreement] The Defendant Company recognizes that the Plaintiff’s mutual aid provisions, etc. apply in entering into mutual aid transaction agreements with the Plaintiff and agrees to the following provisions:

Article 3 (Termination of Mutual Aid Agreement) (5) When the mutual aid contract is terminated, the Plaintiff shall settle and collect the mutual aid premium from the Defendant Company based on the total amount of the actual advance payment from the conclusion to the termination of the mutual aid transaction agreement.

Article 4 (Offset) If the defendant company falls under any of the following subparagraphs, the plaintiff set off the amount of mutual aid money and other damages with the security paid (including contributions) against the defendant company: