1. The Defendant’s succeeding Intervenor (Counterclaim Plaintiff) completed the District Court No. 116637 and No. 11638, Dec. 14, 2012.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The establishment of a right to collateral security and compulsory execution 1) by the Defendant (i.e., the Defendant; hereinafter referred to as the “Defendant”) is the GabongD Co., Ltd. (hereinafter referred to as the “Nonindicted Company”).

(2) On September 14, 2012, the Defendant and the Defendant entered into a mortgage agreement on September 20, 2012, and on December 14, 2012, with respect to the land and buildings listed in the separate sheet No. 2, in order to secure repayment of the loan, respectively, with the Defendant. (2) On December 14, 2012, the non-party company entered into a contract with the Defendant to add machinery and apparatus listed in the separate sheet No. 3 as collateral to the aforesaid collateral security and to convert it into a factory and mining foundation mortgage under Article 6 of the Act on Mortgage on Mortgage on Factories, and accordingly, the Jung-gu District Court concluded the registration of the establishment of each collective security (hereinafter “instant collective security”).

3) On August 21, 2014, when the non-party company delayed repayment of the loan, the Defendant filed an application for voluntary auction with the Jung-gu District Court A on the basis of the instant collateral security on August 21, 2014, and the said court rendered a decision to commence voluntary auction on the land and buildings as stated in the attached Table 2, and the machinery and instruments listed in the attached Table 3, as stated in the attached Table 3 (hereinafter “instant auction procedure”).

B. B. On December 4, 2014, the Defendant entered into an agreement on acquisition of assets with the Yonhap Asset Management Co., Ltd. to sell bad loans.

2) On December 29, 2014, the Yonhap Asset Management Co., Ltd. transferred all the rights and obligations under the above asset acquisition agreement between the defendant and the defendant succeeding intervenor to the defendant to the defendant succeeding intervenor. The defendant succeeding intervenor entered into a contract with the defendant succeeding intervenor to acquire these rights and obligations. 3) The defendant notified the non-party company of the assignment of claims on December 30, 2014 with consent to the above contract and notified the non-party company of the assignment of claims on December 30, 2014, and