1. The Defendant (Counterclaim Plaintiff) paid KRW 36,919,657 to the Plaintiff (Counterclaim Defendant) and its related amount from August 26, 2015 to February 3, 2017.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On November 11, 2009, the Defendant entered into a contract for purchase and sale of land and business rights with the Plaintiff to sell land and business rights (hereinafter “instant project”) on the ground D (16 units of non-permanent housing; hereinafter “instant building”) on the land (hereinafter “instant land”) outside of 3 parcels of land in Ansan-gu, Ansan-si, the Plaintiff entered into a contract for purchase and sale of land and business rights as follows.

(hereinafter “instant sales contract”). Article 1 (Land Price and Method of Payment)

1. Land price (including building permit right): 5 billion won;

2. Contract deposit: 300 million won shall be paid and received at the time of the contract.

3. Part payments: 1.6 billion won shall be substituted by the Plaintiff, and the interest on the loan shall be borne by the Plaintiff after December 15, 2009.

4. Balance: 200 million won shall be paid on December 28, 2009, and 1.5 billion won shall be paid on February 28, 2010 (Provided, That in the event of delay, payment shall be made by adding interest at the rate of 10% per annum to the delayed amount), 1.4 billion won shall be the settlement of payment for the relevant tenement house at the rate of 12 billion won per annum.

(Provided, That the defendant may sell after designating the number of housing units of not more than three floors). Article 2 (Construction and Sale)

1. Construction cost shall be borne by the plaintiff;

2. The expenses for sale in lots shall be borne by the plaintiff, and the defendant shall actively cooperate so that the sale in lots may be smooth;

3. Proceeds from sale shall first be used by the Plaintiff for smooth construction.

Article 3 (Matters of Special Agreement)

4. Only the business income tax generated from the relevant business shall be borne and paid by the plaintiff;

5. To open a bank passbook in the name of the defendant for the smooth operation of the business concerned, and provide the passbook and seal to the plaintiff.

B. The instant land and the instant building was leased 1) In order to secure a total of KRW 1.6 billion of the debt principal on March 6, 2007 and May 26, 2009 on the instant land, the collective security interests-based collective security interests-based collective security interests-based regional livestock cooperatives (hereinafter “Yanyang Livestock Cooperatives”).

(2) The registration of establishment of a new establishment.