A. The status of the parties is the company that runs the insurance business, etc., and the defendant is an insurance solicitor of C who is the plaintiff's insurance agency.

B. (1) The conclusion of an insurance contract, etc. (1) D operated an indoor swimming pool with the trade name “F” on the third floor of the business building in Seongbuk-gu, Seongbuk-gu, Sungnam-si, and on December 24, 2009, entered into a contract with the Plaintiff via the Defendant on December 24, 2009, including KRW 30 million per capita at the time of occurrence of liability for damages due to the operation of a swimming pool, and KRW 30 million per unit, and KRW 300 million per unit. (hereinafter “instant insurance”).

(2) Around February 22, 2012, D requested the Defendant to increase the maximum amount of compensation, and the Defendant changed the maximum amount of compensation for facility owners’ insurance to KRW 50 million per person and KRW 500 million per accident (hereinafter “instant change contract”).

C. (1) On August 24, 2012, H, who was receiving a swimming course at the above swimming pool, suffered bodily injury, such as paralysis, etc., on the ground that he was faced with the head’s swimming pool floor (hereinafter “instant accident”).

(2) H filed a lawsuit against D and Suwon Instructors seeking compensation for damages arising from the instant accident (U.S. District Court 2013Dahap2357). On March 25, 2014, H rendered a judgment ordering D and Suwon Instructors to jointly pay 651,056,984 won and delay damages.

A lawsuit between H and D for compensation for damages was concluded on October 2, 2015 at the appellate court (Seoul High Court 2014Na31020) to provide a minimum of KRW 550,000,000,000.

(3) From October 23, 2012 to August 14, 2014, the Plaintiff paid KRW 50 million in total to H in accordance with the instant insurance.

D's lawsuit for damages against the plaintiff (1) D shall be the plaintiff.