1. Insurance proceeds to the Defendant (Counterclaim Defendant) of the Plaintiff (Counterclaim Defendant) based on each insurance contract listed in attached Table 1.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On May 2010, the Defendant posted the tender proposal, goods specification, etc. for the production and purchase of seven electric trains (56 km) that will be put into the extension section of subway 7 lines (10.2 km from the temperature to the Bupyeong-gu Office Station) on the Defendant’s website. The main contents of the written request for proposal posted by the Defendant are as shown in attached Table 2.

B. On June 11, 2010, the Defendant: (a) concluded a contract for the manufacture and purchase of electric vehicles between the former and the latter (hereinafter “instant main contract”); (b) around June 22, 2010, the manufacturing and purchase of new electric vehicles by the former and the latter for each electric vehicle; (c) around June 22, 2010; (d) entered into a contract for the manufacture and purchase of new electric vehicles by the latter for each new electric vehicle; (e) the manufacture and purchase of new electric vehicle for each new electric vehicle for each new electric vehicle for each new electric vehicle for each new electric vehicle for each new electric vehicle for each new electric vehicle for the latter; (e) the manufacture and purchase of new electric vehicle for each new electric vehicle for each new electric vehicle for each new electric vehicle for the latter; and (e) the main terms of the instant contract for the latter are as follows:

The name of a contract for the purchase of goods (long-term continuing 1): The total amount of a contract for the manufacture and purchase of new electric vehicle for the extended section 7: The amount of electric vehicle: 8,729,903,00 won: the contract amount: the contract amount of KRW 872,990,300: the contract amount of KRW 872,990: the contract amount from June 11, 2010 to June 30, 2012: 10% gold delivery period: the total delivery period on February 28, 2011: the total manufacture amount on March 31, 201: the total long-term contract amount of KRW 8,729,903,000: the amount obtained by deducting the amount already contracted from the total amount of contract after the second year: the scope of the amount calculated by deducting the amount already contracted.

B. On February 28, 2011, 247, 129,129,000 of the electric vehicle 1 1,247,247,247,129,00 of the electric vehicle 3 1,247,129,00 of the electric vehicle 3 1,247,129,000 of the electric vehicle 3 1,247,387,387,129,000 of the electric vehicle 3 3 1,247,247,129,000 on March 31, 2012, 31,741,387,387,000 of the unit price of the contract goods 3 3 3 1,247,129,000 of the electric vehicle 3 3 3 3 3 3 3 3 3 3 3 3 3 ,7 8,729,03,000