1. The Defendant (Counterclaim Defendant)’s obligation based on the construction subcontract on October 30, 2012.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On October 12, 2012, U.S. C Co., Ltd. (hereinafter “SP”) was awarded a contract for the construction cost of C Co., Ltd. (hereinafter “instant construction”) from the Korea Southern Development Co., Ltd. (hereinafter “Korea Southern Development”) to KRW 781,602,150 (i.e., value of supply KRW 710,547,409, value-added tax of KRW 71,504,741).

B. Of the construction cost under the above contract, the material cost is KRW 86,525,641 (i.e., the material cost of KRW 82,983,935 (Miscellaneous material cost of KRW 3,541,706) and the labor cost of KRW 444,344,814 (i.e., the direct labor cost of KRW 404,685,623), the indirect labor cost of KRW 39,65,659,191), insurance premium and retirement pension payment amount of KRW 49,325,851).

C. On October 15, 2012, U.S.C. ordered the instant construction to the Plaintiff on October 15, 2012, the subcontract price was set at the amount equivalent to 75% of the amount calculated by deducting value-added tax, four major insurance premium (national pension insurance, health insurance, employment insurance, industrial accident insurance, and retirement insurance premium) and retirement insurance from the original contract amount.

On October 30, 2012, the Plaintiff ordered the Defendant to re-subcontract the instant construction work, and the re-subcontracted the amount equivalent to 57.4694% of the amount obtained by deducting value-added tax, four major insurance premiums, and mutual-aid insurance premiums from the original contract amount (380 million won).

(hereinafter “instant sub-subcontract”). The main contents of the instant sub-subcontract are as follows:

1. Contract ratio: 57.4694% (380 million won) of the amount excluding the value-added tax, four major insurance premiums, and retirement mutual-aid insurance premiums shall be determined from the amount contracted by the ordering person and the prime contractor;

3. Payment of the price: (1) Payment of the price shall be made within seven days after a claim for the payment of the price is made; (3) The amount of the purchase tax invoice paid by the defendant shall be paid to the defendant;

6. Matters not stated in this contract, such as quantity of materials on the specifications, shall be based on the original contract of the ordering party, and other generated matters shall be governed by commercial practice.