A. The lower court erred by misapprehending the legal doctrine on the calculation of additional collection charges and by misapprehending the legal doctrine, ① the first instance court’s judgment 2015 senior 724 criminal facts 1-4

A. As to the crime of violation of the Act on the Punishment of Acts, Including Mediation, etc. of Commercial Sex Acts (hereinafter referred to as "violation of the Act on the Punishment of Acts, Including Mediation, etc. of Commercial Sex Acts (hereinafter referred to as "violation of the Act on the Mediation, etc. of Commercial Sex Acts") on December 3, 201, the crime of violation of the Act on the Punishment of Acts, Etc. of Arranging Commercial Sex Acts is not average credit card sales per day during the crime period

B. Criminal proceeds are calculated on the basis of the average credit card sales per day during the period of the crime committed in violation of the Act on the Punishment, etc. of Acts of Arranging Sexual Traffic (hereinafter “Offense of Violation of the Act on the Punishment, etc. of Acts of Arranging Sexual Traffic (hereinafter “Crime of Arranging Sexual Traffic, etc.”), and ② the Defendant was issued KRW 3 million per month from Z, AA, AB, etc. (hereinafter “Z, etc.”) during the crime committed in violation of the Act on the Punishment, etc. of Acts of Arranging Sexual Traffic (Crime of Arranging Sexual Traffic, etc.) on February 15, 2012, and even if the Defendant received KRW 25% of the proceeds of the crime committed in accordance with an agreement with Z, etc., the amount equivalent to 25% of the proceeds of the crime committed in accordance with the agreement with Z, etc.

Even in the case related to Z, etc. [Seoul Southern District Court 2014No. 2103, 2015 No. 559 (Joint)] calculated criminal proceeds based on the total amount of credit card sales in 2012, the lower court calculated a surcharge on the basis of the total amount of credit card sales during the crime period. Thus, the lower court erred by misapprehending the facts concerning the surcharge for each of the above crimes or by misapprehending the legal principles on the calculation of the surcharge, thereby adversely affecting the conclusion of the judgment.

B. The punishment sentenced by the lower court (three years of imprisonment) is too unreasonable.

2. As to the assertion of misunderstanding the facts related to the surcharge and misapprehension of the legal principles

A. On December 3, 2011, part 1 of the crime of violation of the Act on the Punishment of Acts, including the Mediation, etc. of Commercial Sex Acts (Good Offices, etc.) is recorded in an investigation report (Calculation of Criminal Proceeds) (Calculation of Criminal Proceeds).