1. The Defendant (Counterclaim Plaintiff) paid KRW 16,991,00 to the Plaintiff (Counterclaim Defendant) and its related amount from December 29, 2012 to February 8, 2017.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On September 4, 2012, the Defendant awarded a contract to the Plaintiff for the new construction of the B Tuldong Factory (hereinafter “instant building”) at the rate of 0.01% per day (01% per day from September 4, 2012 to December 24, 2012, setting the construction cost of KRW 1.65 billion (excluding value-added tax), construction period of KRW 400,000 (excluding value-added tax), and the period of construction from September 4, 2012 to December 24, 2012.

B. On September 8, 2012, the Plaintiff began construction and obtained approval for the use of the instant building on December 28, 2012.

Meanwhile, around March 8, 2013, the Defendant occupied the instant building.

C. From September 11, 2012 to March 27, 2013, the Defendant paid a total of KRW 1.72 billion to the Plaintiff as the instant construction cost.

[Ground of recognition] Unsatisfy, Gap evidence Nos. 1, 2, 4, and 5, the purport of the whole pleadings

2. The fact that the Plaintiff completed the instant construction project; the Defendant paid the Plaintiff KRW 1.72 million as the instant construction cost; the Defendant paid KRW 95 million as the instant construction cost; and the amount of KRW 1.65 million as the agreed construction cost (including value-added tax, KRW 1.65 million as the agreed construction cost; KRW 1.65 million as the agreed construction cost; KRW 1.65 million as the agreed construction cost; KRW 1.620 million as the agreed construction cost; KRW 1.725 billion as the agreed construction cost); the Plaintiff did not pay the agreed construction cost; and the Plaintiff performed the instant construction project equivalent to KRW 7331,50 as the additional construction cost (including value-added tax) from the instant construction project other than the construction project under the agreement (including value-added tax); barring any special dispute between the parties, the Defendant recognized that the said additional construction project executed by deducting the above additional construction cost from the settlement of the construction cost, and thus, barring any obligation to dispute between the parties.

3. The defendant's defense and counterclaim regarding the principal lawsuit

A. As for the construction work executed by the Defendant Plaintiff, the amount of appraisal in the attached Form No. 1 list of defect repair costs is column.