A. On April 2010, the Plaintiff entered into an agency contract with the Patom’s (i.e., the name of the goods) with the Patom’s (i.e., “Patom’s”) on the condition that the Plaintiff sells the clothing goods supplied from the Patom’s (i.e., the name of the goods) and pays the remainder of the goods after deducting the Plaintiff’s sales commission from the sales price to the Patom’s (hereinafter “the primary agency contract of this case”). The Plaintiff deposited KRW 20 million with the Patom’s total sum of KRW 10 million each on April 28, 2010 and May 31, 2010 (hereinafter “the instant deposit”). On April 28, 2010, the Plaintiff set up a collateral security contract with the Patom’s real estate in the name of G with the Patom’s maximum claim amount of KRW 100 million as the maximum claim amount.

B. On July 14, 2010, the Plaintiff notified the Patom’s termination of the instant primary agency contract on July 24, 2010. On the other hand, the Seoul Central District Court decided on September 3, 2010 to commence the rehabilitation procedure (Seoul Central District Court 2010 Gohap93) with respect to the Patom’s decision on September 3, 2010.

C. During the period from September 29, 2010 to October 19, 2010, the Plaintiff reported the instant security deposit refund claim amounting to KRW 20 million as the rehabilitation claim during the aforementioned rehabilitation procedure.

On October 18, 2010, the Plaintiff entered into an agency contract with the Defendant to sell goods in the same manner as the instant primary agency contract (However, the name of the clothing product sold by the Plaintiff is F). Article 19 of the instant secondary agency contract provides that the Plaintiff deposits KRW 20 million with the Defendant as a security deposit in order to secure all obligations owed by the Plaintiff due to the said contract, and sets up a collateral security worth at least KRW 100 million with the maximum debt amount on real estate.

(e).