Defendant (Counterclaim Plaintiff) delivered each real estate listed in the separate sheet to the Plaintiff (Counterclaim Defendant).

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On July 22, 2013, the Plaintiff entered into a lease agreement between the Defendant and the Defendant to lease each of the real estate listed in the separate sheet (hereinafter “instant real estate”) with the term of the lease deposit of KRW 20 million, monthly rent of KRW 2 million (including value added tax; hereinafter the same shall apply), and the term of the lease from July 22, 2013 to July 21, 2016. On July 22, 2016, the term of the said lease was extended from July 22, 2016 to July 21, 2018, the Plaintiff again concluded the same lease agreement with the same terms and conditions (hereinafter “the instant lease agreement”). On July 22, 2013, the Defendant paid the Plaintiff the lease deposit of KRW 200,000,000 (hereinafter “the instant real estate”).

(c)

On April 26, 2018, prior to the expiration of the instant lease agreement, the Plaintiff: (a) planned not to renew the instant lease agreement to the Defendant; (b) accordingly, (c) sent a document verifying the content of the request to deliver the instant real estate immediately after the expiration of the instant lease agreement; and (d) sent a document verifying the same purport to the Defendant on May 2, 2018 and May 21, 2018.

(d)

On May 3, 2018, the Defendant issued to the Plaintiff a certificate to the effect that if it is impossible to renew the instant lease agreement due to the Plaintiff’s demand for renewal, a new lessee shall be entitled to receive the premium for damages.

E. On May 30, 2018, the Defendant: (a) transferred the right to the instant commercial building (facilities) to D; (b) entered into a premium contract with D to receive KRW 250 million with the premium (hereinafter “the instant premium contract”); (c) received the down payment of KRW 2 million from D; and (d) requested the Plaintiff to enter into a new lease contract with D; but the Defendant refused to enter into a new lease contract with D.