A. On July 10, 2008, the Plaintiff entered into an electric use contract with the Korea Electricity Corporation (hereinafter “instant electric use contract”) with the following contents in order to receive electricity necessary for the business of processing and manufacturing waste plastics, and began to receive electricity from around that time.

Type of contract: High-tension A Electrical Power of Ulsan-gun A: 350kW changeers (MOF) capacity for the meter changeers (MOF) capacity: Matters not specified in the contract for the supply of electricity to the Republic of Korea shall be governed by the terms and conditions of the supply of electricity and the detailed rules on the supply of electricity to the Ulsan-gun.

B. On April 1, 2009, the Plaintiff entered into a contract (hereinafter “instant contract”) with Defendant B, which operated an electrical construction business under the name of E in order to increase the quantity of electricity used, under which the Plaintiff entered into a contract with Defendant B, to assign the construction of additional installation of 400 kW transformers at the Plaintiff’s workplace to KRW 33 million (including value added tax) (hereinafter “instant contract”).

(c)

According to the instant contract, Defendant B installed 400kW changeers and instruments changeers (30/5A) at the Plaintiff’s workplace in accordance with the instant contract (hereinafter “instant changeers, etc.”). Upon delegation from the Plaintiff, Defendant B applied for the installation and use of the instant changeers, etc. with respect to the Korea Electricity Corporation, but did not obtain approval from the Korea Electricity Corporation.

(d)

Around June 2017, the Korea Electric Power Corporation discovered that the Plaintiff installed and used the instant transformers, etc. in violation of the contract for electricity use with the Korea Electric Power Corporation without the approval of the Korea Electric Power Corporation, and filed a claim with the Plaintiff on July 20, 2017 for penalty of KRW 1,520,393,905 (hereinafter “instant penalty”). E. The instant penalty is premised on (i) the Plaintiff installed the instant transformers, etc. from April 2009 to April 209.