1. The Defendant (Counterclaim Plaintiff) paid KRW 373,579,769 to the Plaintiff (Counterclaim Defendant) and its amount from May 5, 2017 to January 30, 2019.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. Before the change of the Plaintiff, C, D, and E are N Co., Ltd.

A Co., Ltd., F, G Co., Ltd., H Co., Ltd., I Co., Ltd., J Co., Ltd., J Co., Ltd., Ltd., and K Co., Ltd. (hereinafter referred to as “Plaintiff, etc.”) were awarded a contract for construction works for build-transfer-lease projects (hereinafter referred to as “M”) (hereinafter referred to as “instant construction works”) from L Co., Ltd. (hereinafter “L”) on December 31, 2010 by constituting a joint supply and demand organization with the method of joint performance (hereinafter referred to as “instant joint supply and demand organization”) by setting the construction cost of KRW 356,480,080,00,00 and from December 31, 2010 to April 30, 2014.

Plaintiff

On December 7, 2011, L entered into a modified contract on the said contract. In the said modified contract, K transferred the status of the said contract to the Plaintiff, and the Plaintiff was determined to accept it.

B. 1) On August 23, 2011, the Plaintiff, etc. entered into a joint supply and demand agreement with respect to the instant construction project (hereinafter “instant joint supply and demand agreement”).

The representative of the instant joint supply and demand agreement is the Plaintiff. Article 3(3) of the instant joint supply and demand agreement provides that “The representative shall represent the joint supply and demand organization with respect to the project owner and the third party and shall have the authority to manage the property of the joint supply and demand for payment, etc.” 2) Members of the instant joint supply and demand organization jointly and severally liable for the performance of their contractual obligations to the project owner. The members of the instant joint supply and demand organization ultimately assume the liability for the performance of their contractual obligations to the project owner. The joint supply and demand organization’s share ratio is final 32.89%, C12.5%, E12.5%, D10%, G10%, G10%, H10%, H 10%, F 6%, 13%, J 3%

C. The Plaintiff, C, D, E, F, G, H, I, and J (hereinafter “Plaintiff and eight companies”) are companies engaged in Defendant construction business, stone construction business, stone processing business, stone manufacture, wholesale, trade, etc. on November 7, 2012.

Between the Plaintiff and eight companies, etc.