1. Insurance money of KRW 377,547,972 based on the attached guaranty insurance policy against the Plaintiff (Counterclaim Defendant) by the Defendant (Counterclaim Defendant).

A principal lawsuit and a counterclaim shall be deemed to be combined.

1. The facts falling under any of the following subparagraphs may be found either in dispute between the parties or in full view of the respective descriptions of Gap evidence 1 to 5 (including each number; hereinafter the same shall apply), Eul evidence 2, 3, 8, 9, and 13 and the whole purport of the pleadings:

On October 12, 2010, the Defendant entered into a subcontract (hereinafter “instant subcontract”) with the Maritime Development Co., Ltd. (hereinafter referred to as the “ Intervenor’s Maritime Development”) (hereinafter referred to as the “ Intervenor’s Maritime Development”) with respect to the construction cost for earth and sand, drainage and structures during the said construction period, from October 12, 2010 to February 14, 2012 (hereinafter referred to as the “instant subcontract”).

B. The Defendant and the Intervenor: (a) concluded a detailed contract with each of the following parts of the Corporation regarding the instant subcontract; and (b) subsequent to the conclusion of the third-minute construction contract, in order to secure the Intervenor’s obligation to return advance payment on the remainder of the construction to be paid by the Intervenor to the Intervenor Maritime Development; (c) the Intervenor Maritime Development entered into a guarantee insurance contract with the Plaintiff as the insured, the guaranteed amount of 400,000,000 won, the guarantee period of 27 October 2011 to December 31, 2013 (hereinafter “instant guarantee contract”); (d) the Plaintiff’s Intervenor Supplementary Construction Mutual Aid Association (hereinafter “ Intervenor Mutual Aid Association”); and (e) the Plaintiff’s Defendant, the guaranteed amount of 315,000,000,000 won, and the guarantee period of 31 October 27, 2011 to December 31, 2018.

C. On the ground that the Defendant terminated the instant subcontract as of March 13, 2013, the Defendant made an advance payment on April 1, 2013 regarding the remainder of the construction to be returned from the Intervenor’s piracy Development to the Plaintiff.