The judgment of the court below is reversed.

A defendant shall be punished by imprisonment for two years.

Provided, That the above punishment shall be imposed for three years from the date this judgment became final and conclusive.

1. Summary of grounds for appeal;

A. Legal principles and misunderstanding of facts 1) Defendant C (hereinafter “C”) operated by Defendant

A) A resident with six employees, who work for an office, warehouse, and truck, and who are equipped with two units of office, and the Defendant performed business activities and duties with professional knowledge. The Defendant, mainly referring to the website of the government office, identified the design firm requested to design the construction works ordered by the government office by confirming the details of the ordering plan, the announcement of tender, the result of opening, the current status of contract execution, etc., and conducted business activities so that E products can be reflected in the design business entity. The Defendant is a stock company E (hereinafter referred to as “E”).

A) There is no evidence to deem that the Defendant agreed on the payment of fees under the pretext of arranging the use of friendship or connection with a public official. In light of this, the Defendant actually engaged in business activities against public officials, etc. in order to achieve the common purpose with E as intermediary agent and received money under the pretext of fees. As such, the Defendant is deemed to have dealt with his/her business affairs. (ii) The Defendant’s 192,776,657, which is the amount paid by the Defendant to “Sbro agency”, was operated jointly by the Defendant and the bro agency and distributed its profits, and thus, the Defendant cannot be deemed to have held unlawful profits. Therefore,

B. The Defendant did not recognize that his business method was an unlawful act, and there was no record of punishment.

The Defendant is against the fact that he created a water in this case.

Most of the Defendant's promotional products are selected as excellent products in procurement.

Profits actually earned by the defendant are nothing more than part of the gains.

The defendant shall do so through public relations or design reflection in a normal way.