1. The Plaintiff (Counterclaim Defendant) against the Defendant (Counterclaim Plaintiff)

A. USD 357,526 and USD 269,40 among them.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Facts of recognition;

A. 1) On December 15, 2015, the Defendant entered into a sales contract. On December 15, 2015, the Republic of Korea (R&R EspeJ Cpo Corporation, hereinafter “A&A”) with Al&A of the Philippines.

B B Between the Defendant and 43 Rad TV 3,200 TV and 1,600 TV diskettes 1,600 (hereinafter referred to as “instant cargo”).

(1) The sales contract for the sale of USD 904,00 to Albn for the terms of “CIF (including freight insurance premium)” (hereinafter “instant sales contract”).

2) On February 22, 2016, Alb demanded the issuance of a credit to the Bank Lekii U.S.A. N.Y., (hereinafter “LA”). On March 20, 2016, LAW issued an irrevocable credit that guarantees payment of USD 904,000 with the maturity fixed on March 20, 2016 (hereinafter “the instant credit”), and thereafter, the maturity of the instant credit was extended on May 20, 2016.

B. (1) On April 28, 2016, the Plaintiff entered into an insurance contract with the Defendant to pay insurance proceeds of USD 994,400 ($ 904,00,000, which is the amount of commercial invoice of the instant cargo) to the Defendant where an insured event, such as loss or damage, occurred during the course of marine transportation of the instant cargo, etc. (hereinafter “instant insurance contract”).

(2) The original Defendant agreed to apply the terms and conditions of the instant insurance contract to the Institute Cargo Clause A (hereinafter “instant terms and conditions”), and the main contents of the instant terms and conditions are as follows.

Security Risk

1. This insurance covers all risks of loss or damage that arise for the purpose of the insurance except as provided for in Articles 4, 5, 6, and 7 below.

Provided, That the risks referred to in Articles 4 through 7 shall be excluded.

8.1. This insurance is described in this Insurance Policy in order to initiate carriage of cargo.