1. The Defendant (Counterclaim Plaintiff) paid KRW 374,834,300 to the Plaintiff (Counterclaim Defendant) and its related amount from April 28, 2018 to August 29, 2018.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Facts of recognition;

A. On September 1, 2014, the Plaintiff entered into a contract with the Defendant for the construction of a new factory (hereinafter “instant factory”) (hereinafter “instant construction contract”) under which the construction cost of KRW 3,787,00,000 (excluding value-added tax), the construction period from September 22, 2014 to January 15, 2015 (the scheduled date of commencement) and the construction period of KRW 0.01% (hereinafter “instant construction contract”).

B. On December 10, 2014, the Plaintiff entered into a contract with the Defendant to change the construction period from October 20, 2014 to March 20, 2015 (hereinafter “instant contract”).

C. The Defendant continued and completed the instant construction. The construction permission date for the instant factory was October 13, 2014; the commencement date was October 30, 2014; the permission date for construction alteration was November 18, 2014; and the approval date for use was June 11, 2015.

The Defendant, upon the Plaintiff’s request or approval, added or changed the construction work in addition to the construction work under the instant construction contract and alteration work contract, and the construction work due to the addition or alteration work in addition to the above KRW 3,500,000 is KRW 314,969,00.

Value-added tax to be paid to the Defendant by the Plaintiff in relation to the instant construction contract and alteration work contract is KRW 321,00,000.

The Plaintiff and the Defendant agreed to deduct the H-BEM remaining material cost and Crest construction cost that the Plaintiff supplied to the instant construction from the construction cost after the completion of the instant construction. The final settlement of H-BEM remainder material cost is KRW 130,000,000, and the amount to be deducted from KRW 435,000,000 in total is KRW 565,00,000.

E. From November 17, 2014 to September 2, 2015, the Plaintiff deposited KRW 3,760,000,000 in total as the construction cost of the instant case over 13 times in the Defendant account, as shown in [Attachment 1].

[Attachment 1] Date and time of set.