1. On May 21, 2015, the director of the tax office of Yeongdeungpopool on the Plaintiff, and the director of the tax office of the same orchard on May 20, 2015, respectively.

1. Details of the disposition;

A. The Plaintiff is a corporation of the United States of America (hereinafter “U.S.”) and holds a number of patent rights related to radio Internet technology registered in the United States.

B. Around July 2010, the Plaintiff filed a lawsuit against the instant company in the East Court of the United States for the prohibition of patent infringement and the compensation for damages against the Plaintiff’s patent right (patent number D, E, F, G, H, I, J, K, and hereinafter “instant patent”) related to the Plaintiff’s smartphone radio e-mail transmission technology (patent number D, E, F, G, H, I, K, and the instant patent”).

(hereinafter “instant patent infringement lawsuit”). C.

On May 2012, the Plaintiff and the instant enterprise entered into a patent license agreement and a compromise agreement (hereinafter “reconciliation agreement”) with the main contents of the termination of the instant patent infringement lawsuit and the grant of a patent license to the instant enterprise. According to the said reconciliation agreement, the Plaintiff granted the instant enterprise a license to use the instant patent owned by the Plaintiff, and in return, B granted a license to use the instant patent to the instant enterprise, and in return, B paid US$ 750,000 (amounting to KRW 8,593,500,000), and C paid US$ 480,000 (amounting to KRW 5,392,080,000) to the Plaintiff, respectively.

B On July 13, 2012, C, on July 10, 2012, when paying the Plaintiff the sum of the usage fees of KRW 12,30,00 (hereinafter “instant usage fees”) that are to be paid according to the instant settlement agreement, B, applying the limited tax rate of 15%, B, and C, as corporate tax, withheld US$ 1,125,000 (amounting to KRW 1,289,025,00) and paid US$ 720,000 (amounting to KRW 808,812,00) at the competent tax office, respectively.

E. On January 23, 2015, the Plaintiff constitutes the Plaintiff’s domestic source income since the instant royalty was income for a patent that was not registered in the Republic of Korea.