2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

Defendant.

A. (1) The Plaintiff is a trade union at a national level established with the entire nation’s metal industry and metal-related industry workers, etc. organized, and the Defendant is a company established with the purpose of manufacturing, processing, wholesale and retailing, export and import business of various pulp and paper.

(2) On November 4, 2008, a trade union composed of the employees belonging to the defendant was made a structural change from a company-level trade union to the Korean Metal-nam Branch A branch of the Korean Metal Trade Union (hereinafter the above A trade union and the Korean Metal Trade Union A branch of the Korean Metal Trade Union (hereinafter referred to as the “Plaintiff branch”).

B. On November 15, 2006, Plaintiff Branch of the instant collective agreement concluded a collective agreement with the Defendant (hereinafter “instant collective agreement”) with the Defendant, and Article 1 of the collective agreement stipulates that the Plaintiff Branch of the instant collective agreement shall be the sole negotiating body with respect to the management of collective labor-management relations, such as: (a) on-site workers shall be at the same time as a new employee; and (b) on-site workers shall be members at the same time as a new employee; and (c) the withdrawal of union members shall be subject to the notification of the union; and (d) during the working hours under Article 8, the provision on strengthening the organization and activities of the union regarding union

In addition, Article 1 of the Addenda to the collective agreement of this case provides that the effective period shall be two years, and Article 2 of the Addenda provides that a renewed proposal shall be submitted at least 30 days prior to the effective period and a request for collective bargaining shall remain effective

C. (1) After the expiration and termination of the term of validity of the instant collective agreement, the Plaintiff and the Defendant conducted collective bargaining to renew the collective agreement on 17 occasions from October 23, 2008 to December 16, 2009, but did not reach an agreement on the difference in the position of the union activities clause. As such, the Defendant was judged to be difficult to renew the new collective agreement to the Plaintiff on June 19, 2009.