A. The Plaintiff is an insurer of each insurance contract listed in the separate sheet No. 1 (hereinafter “each of the instant insurance contracts”) with the company running the insurance business, etc.

B. On December 15, 2006, the Defendant purchased each of the instant land C and D (hereinafter “instant land”).

C. On the above ground, there were buildings listed in the attached Table 2 List No. 1 (hereinafter “instant building No. 1”) and buildings listed in paragraph (2) of the above list (hereinafter “instant building No. 2”), and buildings listed in paragraph (3) of the above list (hereinafter “instant No. 3”) on the ground D, and buildings listed in paragraph (3) of the above list (hereinafter “instant building No. 3,” and buildings with the remainder of 96 square meters (hereinafter “instant No. 4”) and unregistered buildings with two different floors (80.07 square meters; hereinafter “instant No. 5”).

The Defendant, while carrying out the wholesale retail business for bicycles and sludge in the 4th floor (unregistered parts) and 5th floor of the instant building, leased the instant building to E, the 2nd building to F (G), the 3rd building to H, and the 1st floor of the 4th building to I (mutualJ) respectively.

E. Meanwhile, the Defendant entered the policyholder and the insured into an insurance contract with the Plaintiff on August 13, 2013 with respect to the foregoing Nos. 1 and 2 buildings, etc., listed in attached Table 1(1), and entered into an insurance contract with respect to the instant Nos. 3 and 4 (registered parts) and the goods and semi-finished goods in the building (in whole and in part) listed in attached Table 2 as stated in attached Table 1(2).

Article 4(1) of the Special Terms and Conditions on the Guarantee of Fire Damage of each of the above insurance contracts provides that "no compensation shall be made for damage caused by the intention or gross negligence of the contractor, the insured, or his/her legal representative."

F. However, around March 17, 2014, a fire (hereinafter “instant fire”) occurred in the instant building around 23:40, and most of the goods, interior facilities, etc. inside the instant building were seriously damaged.

The layout drawing of the building at the fire site of this case is as shown in attached Form 3.

The sequence of each building mentioned above falls under the above drawings.