On June 1, 2010, the Defendant sold to the Plaintiff six parcels of land in Jinju-si, C, D, E, and F, G, and H (hereinafter “instant land”) for KRW 450 million. The Defendant received down payment of KRW 30 million on the day of the contract, and the remainder was to be paid within one month after the completion of authorization and permission on the building to be newly constructed on the said land under the name of the Plaintiff, by establishing a legal entity.

On August 16, 2010, the Plaintiff established the I Co., Ltd. I (hereinafter referred to as “I”) under the name of I, and followed a building permit for automobile-related facilities, etc. on the instant land by obtaining a building permit on January 31, 2011.

On May 3, 201, the Plaintiff: (a) was a holder of the building permit for the instant land; and (b) was working as a representative director, on May 3, 201, the Plaintiff agreed to transfer to the Defendant all the rights to perform construction works in the future under the building permit for the instant land; and (c) drafted a memorandum of agreement (hereinafter “instant memorandum of agreement”); and (d) the main contents are as follows.

o I delegate all the construction rights of the land in this case to the defendant.

o When the defendant pays KRW 300 million by August 10, 201, o I shall transfer the I Corporation to the defendant.

o The I shall submit a written consent to delegation of civil engineering works to the defendant so that the defendant can perform the civil engineering works, accompanied by a corporate seal.

o The defendant shall submit a certificate of borrowing KRW 300 million to the plaintiff who is the representative director of I and shall keep the date of borrowing.

On May 3, 2011, I prepared and provided a written consent for delegation of civil engineering works on the instant land to the Defendant. The Plaintiff and the Defendant around that time prepared a loan certificate of KRW 300 million, the obligee, the borrower, the Defendant, the joint and several surety, J on August 10, 201, the due date for payment, and the interest for arrears at 24% per annum (hereinafter “the instant loan certificate”). On May 3, 2011, the Defendant is limited to KRW 300 million, the mortgagee, and the mortgagee.