1. As to the right to claim the return of share certificates stated in the separate sheet that the Plaintiff (Counterclaim Defendant) has against C institution.

1. Basic facts

A. D Co., Ltd. (hereinafter “Nonindicted Company”) was established for the purpose of manufacturing, selling, and developing computer programs and manufacturing business on January 12, 2010. The Plaintiff is in office as the representative director of the Nonparty Company from the time of its establishment to the date of its establishment. From October 20, 2012 to March 26, 2014, the Defendant served as the auditor of the Nonparty Company and retired on March 31, 2014.

B. When the non-party company success in the development of mobile distribution market and became a supplier partner of the E company, the Plaintiff decided to offer capital increase to the non-party company for enhancing the external confidence of the non-party company and expanding its capital (the “stock allocation method”) on March 2013, but the Plaintiff decided to transfer part of the shares of the non-party company owned by the Plaintiff (the total number of shares issued) to the Defendant and F, who contributed to the relocation of the non-party company’s factory, etc. (the “stock allocation method was selected to prevent the weakening of the existing shareholders’ control right).

C. On April 10, 2013, the Plaintiff transferred 192,588 shares (20% of the total number of shares issued at that time) among the shares of the non-party company owned by the Plaintiff at par value (500 won per share). The Defendant also transferred 48,148 shares (5% of the total number of shares issued at that time) among the shares transferred on April 15, 2013 to G (F) at par value.

Meanwhile, in order to raise the above share purchase price and the capital increase, the Defendant borrowed KRW 250 million from H on April 8, 2013, and the Plaintiff borrowed KRW 300 million from H on April 24, 2014 and KRW 300 million from I (total 60 million).

E. Since then, the non-party company’s capital increase from 481,485,500 won (total number of outstanding shares 962,971 shares) to 1,300,000 won (total number of outstanding shares 2,600,000 shares) by allocating 1,637,029 shares of new shares to shareholders on April 26, 2013 (hereinafter “instant capital increase”) and thereby, the non-party company’s capital increase to 1,30,000 won (hereinafter “instant capital increase”).