1. The Defendant’s imposition of the penalty surcharge of KRW 600,000 against the Plaintiff on February 26, 2019, and the penalty surcharge of KRW 20,000 on April 24, 2019, respectively.

1. Details of the disposition;

A. The Plaintiff is a company that operates urban bus transportation business with a license for passenger transport business in Geumcheon-gu Seoul Metropolitan Government.

B. On February 26, 2019, the Defendant imposed a penalty surcharge on the Plaintiff based on Article 21(12), 85(1)21, and 88(2) of the former Passenger Transport Service Act (Amended by Act No. 15735, Aug. 14, 2018); Article 46(1) and [Attachment Table 5] 18-18 of the former Enforcement Decree of the Passenger Transport Service Act (Amended by Presidential Decree No. 29474, Jan. 8, 2019); Article 44(3) of the Enforcement Rule of the Passenger Transport Service Act [Attachment Table 5] 1-18; Article 44(1) [Attachment 4-1-2] of the Enforcement Rule of the Passenger Transport Service Act (Amended by Presidential Decree No. 29474, Jan. 8, 2019); and Article 44(1) [Attachment 4-1-2] of the Enforcement Rule of the Passenger Transport Service Act.

C. On March 14, 2019, the Defendant issued a disposition to impose a penalty surcharge of KRW 1.2 million on the Plaintiff based on Article 23(1)9, Article 85(1)22, and Article 88(1) and (2) of the Passenger Transport Service Act, Article 46(1) [Attachment Table 5] of the Enforcement Decree of the Passenger Transport Service Act, on the ground that “the Plaintiff violated an improvement order to maintain and manage the CCTV images for at least 15 days from February 19, 2019.”

In addition, on May 13, 2019, the Defendant issued a disposition of imposition of penalty surcharge of KRW 2.4 million (hereinafter “third disposition”) to the Plaintiff on the ground that “the Plaintiff violated the improvement order to maintain and manage the CCTV images for at least 15 days from March 1, 2019.”

On April 24, 2019, the Defendant: (a) stated to the Plaintiff on February 28, 2019 that “the Plaintiff’s route E (F) numbered vehicles (H) operated by the Plaintiff was not in compliance with the cross-border level authorized while operating at G stops (H) around 08:05 on the same day; and (b) while the said vehicle operated by the Plaintiff from K stops (L) around 18:20 on March 6, 2019 to M (N) around 21:0 on the same day.