1. The Defendant’s corporate tax for the business year of November 11, 2011 against the Plaintiff (38,798,640 won and corporate tax for the business year of 2012).

1. Details of the disposition;

A. In order to secure national technology assets and create business opportunities for utilizing intellectual property, the Plaintiff purchased intellectual property rights such as invention and patent as a domestic corporation established on July 23, 2010, with investments from the Government and domestic large enterprises, and engages in the business of granting the right to use them to other corporations.

B. On April 26, 2011, the Plaintiff entered into a contract with the U.S. legal entity that has no place of business in the Republic of Korea to purchase all rights, such as ownership, in relation to the technology patent for the LoED lenses that is registered in nine foreign countries, including the United States and Canada, in nine foreign countries, including the United States and Canada, at USD 200,000.

(hereinafter referred to as “first contract”). (c)

In addition, on July 27, 2012, the Plaintiff entered into a contract with the U.S. corporation that has no place of business in the Republic of Korea to purchase all rights, such as ownership, to the 14th technical patent for semiconductor failure registered in the U.S. (name White Scale Pkage, etc.) of the 14th technical patent for semiconductor failure (name White Pkage, etc. of the invention) registered in the U.S.

(hereinafter referred to as “the instant patent contract”) d. “The First Contract and the First Contract.”

In paying the price under the patent contract of this case, the Plaintiff withheld and paid as corporate tax the amount of KRW 38,798,640, and KRW 339,57,480 (hereinafter collectively referred to as “tax withheld amount”), each of which is 15% of the domestic source royalty income of the U.S. corporations, EDR and GS pursuant to Article 14 of the Convention between the Republic of Korea and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and the Encouragement of International Trade and Investment (hereinafter referred to as “Korea-U.S. Tax Convention”) and Article 93 Subparag. 8 of the former Corporate Tax Act (amended by Act No. 11603, Jan. 1, 2013).

E. Afterward, the Plaintiff asserts that the price for the patent contract of this case is not subject to corporate tax payment, and the entire amount of withholding tax of this case.