1. In relation to the treatment in the attached Form 3, each insurance contract listed in the attached Forms 1 and 2 against the defendant of the plaintiff.

1. Facts of premise;

A. On February 25, 2011, the Plaintiff concluded, respectively, the insurance contracts listed in attached Form 1 with the insured as the Defendant, and the insurance contracts listed in attached Form 2 around June 26, 2012 with the insured as the Defendant, respectively.

B. Each insurance contract listed in the attached Forms 1 and 2 includes cancer surgery expenses with the content that the insured shall pay 20% of the purchase amount of insurance to 3 million won and 80% of the purchase amount of insurance to 3 million won for each surgery where the insured undergoes a surgery for the direct purpose of cancer treatment after the lapse of at least one year from the date of each insurance contract, and the content that the insured shall pay 3 million won of the purchase amount of insurance only once.

C. Around July 18, 2013, the Defendant received a written diagnosis of spaculf type at the Macule University Hospital and received a spaculf type on or around July 26, 2013, and filed a claim with the Plaintiff for the payment of insurance proceeds under the instant 1 and 2 insurance contract. The Plaintiff paid KRW 30,100,000 insurance money in the name of cancer diagnosis expenses, cancer daily hospitalization expenses, but the Defendant did not receive an operation directly aiming at cancer treatment, based on each insurance contract listed in attached Tables 1 and 2, and the part II of the cancer surgery expenses and cancer surgery expenses.

한편, 별지 1, 2 기재 각 보험계약의 암수술비Ⅰ 특별약관과 암수술비Ⅱ 특별약관(이하 위 각 특별약관을 통틀어 ‘이 사건 약관’이라고 한다)은 ‘수술’의 정의와 장소에 관하여'병원 또는 의원의 의사에 의하여 암의 치료가 필요하다고 인정한 경우로서 자택 등에서 치료가 곤란하여 국내의 병원, 의원 또는 이와 동등하다고 인정되는 국외의 의료기관에서 의사의 관리 하에 치료를 직접적인 목적으로 의료기구를 사용하여 생체(生體)의 절단(切斷, 특정부위를 잘라내는 것), 절제 切除, 특정부위를 잘라...