1. The Seoul Guarantee Insurance Co., Ltd. between the Plaintiff (Counterclaim Defendant) and the Defendant Seoul Guarantee Insurance Co., Ltd.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. Defendant A, upon entering into a contract for construction works, has the E Corporation (hereinafter “instant construction work”) to remodel the above ground Cel (hereinafter “existing building”) to D hotel in order to remodel it into D hotel at Pocheon-si. In March 12, 2014.

(2) As to the construction period, the construction period was set from March 12, 2014 to July 17, 2014, and the construction cost was set at KRW 2.5 billion (value-added tax) (hereinafter “instant construction contract”). The following special agreements were concluded:

Article 39 (Matters of Special Agreement) Other matters not specified in this contract may be determined by a separate special agreement between the contractor and the contractor.

1. The total cost: 2.5 billion won, part of the down payment and intermediate payment shall be paid out of a bank loan;

2. Amount paid at a bank of down payment and intermediate payment: 1.4 billion won.

3. The remainder amounting to 1.1 billion won shall be paid by the building owner within 30 days after completion.

(1) A contractor shall complete the completion of responsibility for the execution of all construction processes.

(2) Loan interest expenses and costs shall be paid by a contractor.

[The amount to be paid by the contractor to the owner at the time of the loan of 1.4 billion won to the 1.4 billion won.

On March 12, 2014, the Plaintiff entered into a guarantee insurance contract (contract) with the Defendant Seoul Guarantee Insurance Co., Ltd., with respect to the instant construction project, and concluded a guarantee insurance contract with the Defendant A and the insurance period from March 12, 2014 to July 17, 2014; the contract amount of KRW 275 million; and the terms and conditions of the guarantee determined each as the contract bond under the construction contract.

(hereinafter “instant insurance contract”). C.

(1) On March 2014, the Plaintiff commenced the instant construction work and suspended the construction work on April 2014. (2) Defendant A notified the Plaintiff on March 12, 2015, and on March 30, 2015, the Plaintiff could achieve the purpose of the instant construction contract due to the unilateral discontinuance of construction work.