A. The Defendant is an implementer of “A zone urban development project” in which an urban development project is implemented with respect to the land of Suwon-si District C in accordance with the Urban Development Act.

B. On June 29, 2006, the Defendant obtained authorization of an implementation plan for an urban development project in a zone A, and obtained authorization of a replotting plan on August 10, 2007, and designated a land substitution plan in accordance with the above replotting plan. At the time, the Defendant: (a) designated a land substitution plan in accordance with the above replotting plan; (b) as a right area, 496.8 square meters per 376.3 square meters per land substitution as a land substitution plan; and (c) subsequently, intended to grant a land substitution settlement money later.

C. On October 6, 2009, the Plaintiff entered into a contract with F, G, and H (hereinafter “F, etc.”) to sell the E-slot substitute lot size of the instant land prior to the instant replotting in KRW 2.8 billion. At the time, the Plaintiff entered into a special agreement with the effect that “the Plaintiff has the right to land substitution, and the settlement money due to flat replotting belongs to the Plaintiff at the time of the Defendant’s replotting disposition.” On November 3, 2009, the Plaintiff completed the registration of ownership transfer of F, G, H-Co (F 2/4 shares, G, and H 1/4 shares) with respect to the instant land prior to the instant replotting.

However, as to the whole land before the land substitution of this case, Suwon District Court I followed the real estate auction procedure, and the independent party intervenor (appointed party intervenor) and the designated party (hereinafter referred to as the "participating party") have been awarded a successful bid on November 13, 2014, and paid the price and completed the registration of ownership transfer for each share in the land before the land substitution of this case on the same day.

E. On November 25, 2015, following the completion of construction works on the said urban development project, the Defendant: (a) determined 496.8 square meters of land prior to the instant land substitution as a right area; and (b) determined 376.3 square meters of land J as a substitute lot; and (c) caused by the reduction of land substitution.