A. (1) On July 7, 2011, the Plaintiff was awarded a contract for the Defendant’s new construction of the Defendant’s factory located in the Docheon-si, Docheon-si, Gacheon-do, and ten parcels of land, from the Defendant, for the amount of KRW 3.95 billion in the construction cost (value added tax) and completed the construction work around October 2012.

(2) On October 12, 2012, the Defendant approved that the Plaintiff has the obligation of KRW 3.85 billion to the Plaintiff with respect to the instant construction cost, and concluded that the said obligation is divided and up to November 13, 2012, KRW 1.29 billion by the end of July 2013, 2013, KRW 390 million by the end of February 2014, KRW 390 million by the end of February 39, 2014, KRW 390 million by the end of February 2014, KRW 390 million by the end of May 39, 2014, KRW 390 million by the end of August 39, 2014, KRW 390 million by the end of August 39, 2014, and KRW 390,000,000 by the end of August 20, 2014.

(3) After February 1, 2013, the Defendant paid a cash of KRW 500 million to the Plaintiff on or around February 1, 2013, and transferred a national tax refund claim of KRW 265 million against the Republic of Korea to the Plaintiff.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 3, Eul evidence 13 and 4 (including paper numbers), the purport of the whole pleadings

B. (1) According to the above facts of recognition, barring any special circumstance, the Defendant is obligated to pay the Plaintiff the instant construction cost of KRW 3.85 billion (= KRW 3.8 billion - KRW 500 million - KRW 265 million - KRW 500 million). In order to secure the claim for the said construction cost, the Plaintiff may file a claim against the Defendant for the creation of mortgage on the real estate indicated in the attached list, which is the object of the Corporation, pursuant to Article 666 of the Civil Act. The fact that the duplicate of the complaint of this case, including the Plaintiff’s declaration of intent to exercise the right to demand mortgage, was delivered to the Defendant on August 19, 2015, is apparent in the record, and the Defendant is a claim against the Plaintiff on the real estate stated in the attached list.