1. The Defendant (Counterclaim Plaintiff) paid KRW 284,609,246 to the Plaintiff (Counterclaim Defendant) and its related amount from January 14, 2016 to August 24, 2017.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. The Plaintiff entered into a subcontract agreement with the Defendant on April 3, 2015 (hereinafter “instant contract”) with respect to the instant construction project, upon receiving a contract for the instant construction project from Cercon Construction Group Co., Ltd. (hereinafter “instant construction project”).

At the time of conclusion of the above subcontract agreement, the Plaintiff and the Defendant respectively prepared the standard subcontract agreement for construction works, construction contracts, special conditions, and special terms as follows:

Standard subcontract agreement for construction works (basic)

1. The ordering person: The name of the prime contractor, Inc., the Maercon Construction Group A; and

2. The name of subcontracted project: Earth from among A-built projects.

3. Construction site: At the time of Gyeongnam-si, B and C (two parcels);

4. Period of construction: April 13, 2015, completion September 19, 2015.

5. Contract amount: 2,440,254,00 won: Value-added tax of 2,300,000,000 won: 140,254,00 won; and

6. Payment of the price;

(a) Advance payment: No one; and

(b) Amount completed: (1) Method of payment at the end of each month after the receipt of the original contract: 100% in cash; and (2) Method of payment at the end of each month;

7. Item and quantity of material to be paid: The site descriptions, contracts, and estimated special products, shall be based on the provisions of those.

8. Contract bond: 244,025,500 won; and

9. Warranty bond rate: 3%: 11% (number of days) of the Framework Act on the Construction Industry: The rate of liquidated damages for delay: 0.1% (number of days) of the standard subcontract for the construction works, and Article 7 (Contract Execution Guarantee and Contract Payment Guarantee) (1) of A and B shall guarantee each other the execution of the contract and the payment of the contract price according to the methods falling under any of the following subparagraphs:

1. Article 11 (Inspection of Construction Materials) (1) of the contract performance guarantee of an amount equivalent to 10% of the contract amount to A, shall be new materials to be used for the Corporation, and quality, name, etc. thereof shall be consistent with the design documents;

Article 25 (Cancellation and Termination of Contracts) (1) A or B shall, in the case of any of the following subparagraphs, be notified in writing for a fixed period of time or month to perform the contract and then for that period.