A. The Plaintiff is a company established by the Tentieth International Corporation (hereinafter “FOX”) of the United States for the purpose of importing and distributing movies in the Republic of Korea.

B. On October 1, 2002, the Plaintiff entered into a licensing agreement (hereinafter “instant previous agreement”) relating to film distribution activities in the Republic of Korea with the TRC (hereinafter “TCF”), and according to the instant previous agreement, the Plaintiff, a license, is obliged to pay royalties calculated by the following methods to the TF, a license:

Ratti = Total sales amount of the Plaintiff - Distribution commission - Direct distribution expenses (specific contents of each item shall be deemed to be followed).

C. On July 1, 2008, the Plaintiff entered into a license agreement under which the instant previous contract was amended with the TF (hereinafter “instant modified contract”). According to the instant modified contract, the Plaintiff is obliged to pay royalties calculated by the following methods to the CF:

Latti = Total Sales of Plaintiff - Amount equivalent to a ratio of total sales - Direct distribution expenses - Adjustment amount considering the Plaintiff’s operating profit ratio (the specific contents of each item shall be deemed to be followed).

D. From May 20, 2005 to September 29, 2008, the Plaintiff imported film for film (the import declaration number 41309-05-210742, et al., hereinafter “instant product”) from TF, and paid the value-added tax by reporting royalties to the Defendant, who is the customs collector, at the provisional price and paying the value-added tax, after the Plaintiff’s total sales and payment have become final and conclusive, remitted royalties under the instant previous contract and revised contract, and settled the value-added tax by reporting the final price.

E. The Defendant conducted a follow-up examination of the Plaintiff around 2010 and performed advertising expenses incurred by the Plaintiff.