1. C Work in 2018 between the Plaintiff (Counterclaim Defendant) and the Defendant (Counterclaim Plaintiff), D and E Section 1.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On April 2018, the Plaintiff, among the Defendant, manufactured and supplied materials from the Defendant, and the Plaintiff entered into a contract for the contract for the repair of defects (hereinafter referred to as “the initial contract”) with the period of KRW 840,000,000, totaling from July 1, 2018 to October 30, 2018, for the construction of D and E Complex, among the apartment complexes located in the king-si F (hereinafter “instant apartment”), from among those constructed by C, the Plaintiff purchased materials from the Defendant, and entered into a contract for the repair of defects (hereinafter referred to as “the initial contract”).

B. Around June 2018, the Plaintiff entered into a contract with the Defendant for the production and supply of main households and fish equivalent to KRW 415,000,000 (value-added tax) in total from July 1, 2018 to December 31, 2018 (hereinafter “amended contract”).

C. On November 23, 2018, the Plaintiff entered into a contract with the Defendant to modify the content of producing and delivering the main household and fish equivalent to KRW 358,500,000 (excluding value-added tax) in total from July 1, 2018 to December 31, 2018 (hereinafter “instant contract”). Accordingly, the Plaintiff produced the main household and fish and supplied it to the Defendant by December 31, 2018.

On December 31, 2018, the Plaintiff entered into an insurance contract with G Co., Ltd. for the performance guarantee of defects with the insurance period from December 31, 2018 to December 30, 2021; and KRW 35,850,000 with respect to defects arising from the goods supplied under the instant contract.

E. On June 20, 2019, the Defendant claimed KRW 35,850,000 for insurance money on the ground of the Plaintiff’s failure to repair defects.

F. Meanwhile, between H (mutual name) and H on October 25, 2018, the Defendant established the main household, etc. supplied by the Defendant from the Plaintiff, etc. in the E-Industrial Complex among the instant apartment units.