A. B, as the owner of land of 303 square meters in Subdivision-gu, Sungnam-si (hereinafter “1 land”), obtained a building permit to construct multi-household housing (hereinafter “multi-household housing”) on the ground of the land No. 1 on March 27, 2014. On April 18, 2014, D transferred the ownership of land to D Co., Ltd. (hereinafter “D”) on June 13, 2014; D completed the construction of the first house on September 5, 2014 following the change of the owner’s name on the first house on June 13, 2014.

(hereinafter referred to as the "First Housing Site Development Project"). (b)

On the other hand, the non-party E, as the owner of the land of 2,492 square meters in aggregate (hereinafter “second-party land”) other than the F of the Subdivision-gu, Sungnam-si, and four parcels, obtained a building permit to build a detached house (multi-family house) on the second land on December 30, 2016. The non-party E transferred the ownership of the second land to D and the owner of the building was changed to D on February 13, 2017. D around March 2017, obtained a building permit to build a multi-family housing (multi-household multi-family housing; hereinafter “second-party housing”) on the second land from the Defendant.

C. On April 6, 2017, D concluded a management-type land trust contract for the purpose of constructing two houses (49 households) on the ground of the second land between the Plaintiff (the company name G G Co., Ltd. at that time) and leasing and disposing of them to the beneficiary.

Accordingly, the Plaintiff completed the registration of ownership transfer on land No. 2 on April 10, 2017 due to trust, and completed the registration of ownership transfer on May 4, 2017, and obtained approval for use after completing the second house on April 1, 2018.

(hereinafter referred to as "second-class housing site creation project". (d)

Each location and airline of the land(s) and of the second land(s) shall be as follows:

E. On December 18, 2018, the Defendant: (a) Article 5(2) of the Restitution of Development Gains Act for the Plaintiff; and (b) Article 4(1) of the Enforcement Decree of the same Act for the first and second projects (hereinafter “Development Gains Restitution Act”);