1. The Plaintiff (Counterclaim Defendant) and the Defendant-Counterclaim Plaintiff A, which entered into on August 1, 2008, non-dividend V-Dex pension insurance.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Presumed factual basis

A. The Defendants, among siblings, were solicited by C, an insurance solicitor of the Plaintiff, to purchase an insurance policy.

On August 1, 2008, Defendant A entered into an insurance contract with Defendant A, the insured, the monthly insurance premium A, the insurance period of KRW 9,850,00, the insurance premium payment period of KRW 5 years, the insurance period of KRW 600,000, and non-paid personal pension type personal insurance contract (hereinafter “instant Type 1 insurance”); Defendant B entered into an insurance contract with each of the instant insurance contracts with Defendant B, the insured D, the monthly insurance premium of KRW 9,850,00,00, the insurance premium payment period of KRW 5 years, the insurance period of KRW 600,000,000, the insured amount of KRW 600,000,000, in total, the insured amount of KRW 5-d variable pension type insurance contract (hereinafter “instant type 2 insurance”); and Defendant B entered into an insurance contract with each of the instant insurance contracts with each of the instant types 1.

B. The major terms and conditions of each of the instant insurance contracts are as follows.

Article 5 Definitions

1. The term "amount-variable insurance" means insurance that changes the amount of insurance proceeds, etc. during the insurance period by raising a part of the insurance premiums paid by a contractor in a company to operate it as a special account, and allocating investment profits to the contractor according to the performance records of the special account;

Article 6 (Delivery of Terms and Conditions and Obligation to Explain) When concluding a contract, (1) A company shall disclose to the contractor a copy of the terms and conditions and the written subscription and shall explain the important contents of the terms and conditions.

(2) If a company fails to deliver to the contractor the copies of the terms and conditions to be provided under paragraph (1) or fails to explain the important details of the terms and conditions, or if the contractor fails to affix his/her own signature and seal (including the stamped and the certified digital signature by the licensed certification authority under subparagraph 10 of Article 2 of the Digital Signature Act at the time of concluding the contract, the contractor shall be three months from the date of application.