1. On December 20, 2016, the Plaintiff (Counterclaim Defendant) filed against the Defendant (Counterclaim Plaintiff) for KRW 386,407,793 and interest.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. C Co., Ltd. (hereinafter “C”) entered into a sales contract with D (hereinafter “instant sales contract”) with the content that supply the storage batteries produced by C to D and sell them to the consumers of members of Bupyeong-gu Incheon Metropolitan Government (hereinafter “Seoul”) around 199.

B. Meanwhile, in order to secure the performance of the goods price obligation to D under the sales contract of this case, the Plaintiff signed the registration of the establishment of the neighboring real estate set forth in the attached Table No. 3 of April 15, 199 as C, ① the maximum debt amount of 48,00,000,000, the debtor D, and the mortgagee C, ② the maximum debt amount of 120,000,000, the debtor D, and the mortgagee with respect to each real estate set forth in the attached Table No. 1 and No. 2 of July 7, 1999 as a joint and several surety, and signed the registration of the establishment of each neighboring real estate set forth in the attached Table No. 1 and No. 1 of the attached Table No. 1 and No. 2 as C (hereinafter collectively referred to as the “the registration of the establishment of each neighboring real estate set forth in each of the above cases”).

C. C changed the trade name to E Co., Ltd. on January 13, 2000, and E Co., Ltd. was merged with F Co., Ltd. on January 2, 2009 (hereinafter “F”).

F changed the trade name to G Co., Ltd. (hereinafter “G”) on May 8, 2013.

B. On November 1, 201, F entered into a product supply contract with the content that F sells the storage batteries supplied by F (hereinafter “instant product supply contract”) with D (hereinafter “instant product supply contract”); and the instant product supply contract and the instant sales contract, collectively, “instant agency contract”).

The plaintiff asserts that there is no signature of H, the representative director of D in the product supply contract of this case, and D does not keep the product supply contract of this case.