1. The Defendant (Counterclaim Plaintiff) paid KRW 162,771,951 to the Plaintiff (Counterclaim Defendant) and its related amount from October 1, 2014 to November 6, 2015.

1. Basic facts

A. On May 29, 2005, the Plaintiff (including value-added tax) determined the construction period from June 1, 2008 to October 20, 2008 as the construction period of the D Factory Construction Corporation B (hereinafter “instant construction”) and received contracts from A on May 29, 2005.

(hereinafter “instant contract”).

The main contents of the instant contract are as follows.

Article 27 (Compensation for Delay) (1) In the event that the plaintiff fails to complete the construction work within the deadline for completion, the amount calculated by multiplying the contract amount by the rate of the liquidated damages in the contract (hereinafter “compensation for delay”) shall be paid to the defendant for each number of days in delay.

Provided, That where a completion inspection has been delayed due to a cause attributable to the defendant and where construction has been delayed due to any of the following causes, the penalty for delay equivalent to the number of relevant days need not be paid:

1. Cases due to force majeure events prescribed in Article 18;

2. Where it becomes impossible to proceed with construction works because the supply of important materials that the plaintiff is unable to use as a substitute has been delayed due to a reason attributable to the defendant;

3. Where the commencement of construction has been delayed or suspended due to reasons attributable to the defendant;

4. In case where the execution has been interrupted due to other causes not attributable to the plaintiff's liability. (3) The defendant may set off the liquidated damages calculated under paragraphs (1) and (2) against the construction price paid to the plaintiff under Article 25.

Matters of special agreement

(a) Common matters:

1. The details were based on the drawings received on April 14, 2008, and the details other than those are separate.

2. The particulars of this construction have been limited to the building in the nature of this construction and any appurtenant work other than the building shall be excluded from this contract.

3. The period of construction shall be four months from the commencement date of the construction project (excluding the period of 15 months for the summer and 5 days for the latest holiday);

4. Any works during the period of construction;