1. The Defendant (Counterclaim Plaintiff) against the Plaintiff (Counterclaim Defendant)

(a) entry in paragraph (d) of Article 2, of each ground listed in the list (attached Form 1);

A principal lawsuit and counterclaim shall also be deemed a principal lawsuit and counterclaim.

1. Basic facts

A. On February 13, 2007, the network E entered into a lease agreement between the Defendant and the Defendant on a rent of KRW 3,500,000 per annum and the lease period of KRW 15,622 square meters of C forest land (hereinafter “forest land before division”) (hereinafter “the lease agreement”) with the Defendant on a set of five years from the date of entering into the lease agreement (hereinafter “the lease agreement”). At that time, the forest land before division was delivered to the Defendant.

B. On April 11, 2007, the forest land before subdivision was divided into C forest land of 10,663 square meters (hereinafter “C forest”) and D forest land of 4,959 square meters (hereinafter “D forest”), and the forest land of 10,663 square meters (hereinafter “C forest”) was divided into C forest land and D forest. In addition, C forest land and D forest are collectively referred to as “each of the instant forest land”).

C. On December 12, 2007, the network E donated C forest land among forest land divided as above to the Plaintiff, and completed the registration of ownership transfer on December 18, 2007 to the Plaintiff.

Since then, on April 24, 2012, the Plaintiff entered the Defendant as the Defendant each of the instant forests, even though the lease contract for the second lease contract (No. 4-2) was prepared after the subdivision of the instant forest, the lease property is limited to C forest. However, the area was approximately approximately 800 square meters under the lease contract for the first lease contract (No. 4-1).

However, at the first date for pleading, the Plaintiff stated to the effect that the leased object under the second lease agreement was the entire forest of this case. While seeking a return of unjust enrichment on the whole forest of this case by filing an application for modification of the purport of the claim, the Plaintiff sought a return of unjust enrichment on the basis of the annual rent of KRW 4,000,000 for each of the forest of this case under the second lease agreement. If the leased object under the second lease agreement is only C forest, the Plaintiff as well as seeking a return of unjust enrichment on the C forest of this case, the amount of KRW 4,00,000 per annum.