Issuance of the stock certificates attached under the National Tax Collection Act and request for extradition;

The Plaintiff may claim against the Defendant for the issuance of share certificates on behalf of the Defendant’s shareholder in default.

Article 41(2) of the National Tax Collection Act

2016da 56887 Action for the issuance of share certificates, etc.

Korea

City*** Company

1. The defendant shall issue the share certificates with respect to 7,900 common shares per share of 10,000 common shares issued by the defendant in the future of this AA (O.O.S.) and deliver them to the plaintiff.

2. The costs of the lawsuit are assessed against the defendant.

3. Paragraph 1 can be provisionally executed.

Cheong-gu Office

The same shall apply to the order.

1. Facts of recognition;

A. ThisA holds 7,900 common shares of the defendant (hereinafter referred to as "the shares of this case"), and the defendant did not issue the shares of this case until now.

B. On August 18, 2016, the Plaintiff’s taxation claim against EA was subject to enforcement claim, and seized the instant shares of EA, notified the Defendant thereof, and the notification was served to the Defendant around that time. ThisA was served on the Defendant on October 31, 2016. ThisA defaulted in national taxes of KRW 111,862,720 as of October 31, 2016.

(Reasons for recognition) Facts without dispute, entries in Gap evidence 1 through 3, the purport of the whole pleadings.

2. Determination

Since a company issues share certificates without delay after the incorporation or the due date of new shares (Article 355(1) of the Commercial Act), shareholders may file a claim against the company for the issuance of share certificates, and compulsory execution against the rights to shares before the issuance of share certificates shall be effected by issuing an order to deliver the shares to the execution officer entrusted with the shareholder's share certificates if the company issues share certificates after the shareholder who is the debtor attached the right to claim the issuance of share certificates against the company (see Supreme Court Order 73Ma32, Dec. 28, 1974). In addition, when the Plaintiff seized a claim for the collection of delinquent national taxes, it may subrogate the obligee who is the delinquent taxpayer (see Article 41(2) of the National Tax Collection Act).

Therefore, the Plaintiff may file a claim against the Defendant for the issuance of the instant share certificates on behalf of the Defendant, who is a shareholder of the Defendant. Accordingly, the Defendant is obligated to issue the instant share certificates to thisA and deliver the said issued share certificates to the Plaintiff, who is the subrogation of the delinquent taxpayer of thisA.

3. Conclusion

The plaintiff's claim is accepted.