1. All of the counterclaims of this case shall be dismissed.

2. D corporation between the Plaintiff (Counterclaim Defendant) and the Defendant (Counterclaim Plaintiff).

1. Basic facts

A. On April 16, 2015, A Co., Ltd. (hereinafter “A”) entered into an agreement with the Defendant to transfer A’s current and future goods payment claims (hereinafter “the instant goods payment claims”) against D Co., Ltd. (hereinafter “D”) to the Defendant in order to secure the Defendant’s obligation for the purchase of goods equivalent to KRW 10,078,89,050 with respect to the Defendant, and to grant the Defendant the right to notify the assignment of claims (hereinafter “instant contract for transfer of claims”).

B. On March 23, 2018, upon filing an application for commencing rehabilitation procedures with the Daejeon District Court 2018 Gohap5011, A was decided to commence rehabilitation procedures on April 13, 2018 (hereinafter “instant decision to commence rehabilitation procedures”), and the Plaintiff, a representative director of A, was deemed a custodian of A by the said court.

[In this process, on March 28, 2018, the Daejeon District Court rendered a ruling of comprehensive prohibition order prohibiting compulsory execution, provisional seizure, provisional disposition, or auction procedure for the exercise of a security right based on a rehabilitation claim or rehabilitation security right until a ruling on application for commencement of rehabilitation procedure on the above case is made (hereinafter “decision of comprehensive prohibition order of this case”).

(C) The above decision was sent by public notice on March 29, 2018.

At the time of the decision to commence the instant rehabilitation procedure, the instant claim for the price of goods remains in KRW 187,482,926, but the Defendant, after the decision to commence the instant rehabilitation procedure, notified D and E Co., Ltd. of the transfer of the instant claim for the price of goods based on the instant claim security agreement (hereinafter “instant assignment notification”).

In the rehabilitation procedure of this case, the Defendant reported a claim equivalent to KRW 6,388,267,773 against A (i.e., the claim secured by the assignment of claims, including the claim secured by the goods in this case, KRW 6 billion), as a rehabilitation security right. However, the Plaintiff reported a claim equivalent to KRW 388,267,773, including the claim secured