1. The Defendant (Counterclaim Plaintiff) KRW 4,023,374 from the Plaintiff (Counterclaim Defendant) and its related amount from October 31, 2014 to June 28, 2016.

1. Basic facts

A. On June 1, 2012, the Plaintiff entered into a mining contract (hereinafter “instant contract”) with the Defendant on June 1, 2012, with the content that: (a) the Plaintiff shall engage in mining operations at the Defendant’s D business offices located in C, the Plaintiff shall do so at the Defendant’s D business offices located in C, such as mining operations, ordinary caring operations, and internal transportation; (b) the Defendant shall pay the Plaintiff KRW 2,560 per ton of the tin tin tin tin mined, and 1,920 per ton of the treated tin tin tin, respectively, and the amount of production shall be the quantity recognized by the Defendant and the amount calculated according to the Defendant’

B. Under the instant contract, the Defendant paid mining service costs to the Plaintiff on the basis of the waste stone quantity calculated by subtracting 2,500 tons from the waste stone quantity examined by the head of the D Business Department E, an employee of the Defendant, according to the instant contract.

C. On June 8, 2012, in order to secure the Defendant’s obligation for mining operations under the instant contract, the Plaintiff completed on June 1, 2012, the registration of the establishment of a neighboring mortgage (hereinafter “registration of the establishment of a neighboring mortgage”) of the maximum debt amount of KRW 100 million, which was based on the mortgage contract, on the real estate indicated in the attached list, to secure the Defendant.

On the other hand, on October 18, 2013, the Defendant notified the Plaintiff of the termination of the instant contract on the ground that: (a) in collusion with the head of the production department E of the pertinent D Business Office and the representative director F of the Plaintiff, the Defendant would make the Plaintiff pay excessive waste stone disposal expenses to the Plaintiff on the ground that the Plaintiff would unfairly excessive disposal of waste stone from June 2012 to October 2013.

E. On July 16, 2015, in this court, the Defendant paid the cost of disposal from the Defendant to the Plaintiff according to the volume of waste that he/she saw at the place of business, which is the Defendant’s place of business, as the production department. Thus, despite the duty to examine the volume of waste accurately and prevent the Defendant from causing any damage, the Plaintiff at the said place of business from June 2012 to October 2013, in violation of the above duty.