1. Of the instant counterclaim, the term “a name similar thereto” as stated in paragraph (b) of Article 2 of the purport of the counterclaim.

1. Basic facts

A. The defendant is a news agency under the Act on Promotion of News Communications, which is established for the purpose of publication of communications and news providing business, and provides domestic and foreign news to public offices, etc., and the plaintiff is a local newspaper company that runs the business of publishing and editing periodicals, Internet newspaper business, etc.

B. On July 13, 2007, the Defendant entered into a contract for the operation of H news gathering headquarters (hereinafter “instant news gathering headquarters”) with I on the main contents as follows (hereinafter “instant operating contract”).

Article 1 (Contents of Business) B (hereinafter referred to as “B”) shall conduct the business of providing news communications to the media in the J region under its jurisdiction, government offices, etc. with respect to news communications provided by “A” (the Defendant; hereinafter referred to as “A”).

Article 2 (Jurisdiction Area) The jurisdiction of Article 2 (Jurisdiction Area) shall be J area.

Article 3 (Operation, etc. of news Collection Headquarters) (1) B shall select news reporters in accordance with the code of ethics for editing as determined by Gap and obtain approval from Gap.

(2) Eul shall operate the news gathering headquarters office as recommended by Gap, and news coverage and supply Gap with news in the area under his/her jurisdiction.

Article 5 (Use of Trademark and Trade Name) A shall use A’s trademark during the term of this Agreement and may use the word “B” or “C” in its trade name.

Provided, That if necessary, A may restrict the scope of use of the trademark and trade name of B.

Article 6 (Accumulation of Security Deposit) (1) B shall reserve 150 million won to A in order to secure obligations arising out of this Agreement and contracts incidental thereto.

Article 8 (Payment of Fees) (1) A shall pay 10% of the total monthly sales to A as fees.

Article 10 (Duty to Report Operation) A may, if necessary, request B to prepare and submit a business report on the form designated by A.