1. On September 22, 2014, the Defendant Lessee (Counterclaim Plaintiff) received workplace cancer and livers under diagnosis by the C Hospital on September 22, 2014.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On August 3, 2012, the Defendant concluded with the Plaintiff the Vietnam Health Insurance Contract (hereinafter “instant insurance contract”), such as the insurance contract in the attached Form, for non-dividend dividends.

The insured of the instant insurance contract is the defendant, and the beneficiary is the defendant (other than death) and the legal heir (the time of death).

At the time of the instant insurance contract, there are “a disability after disease” in the collateral items to which the Defendant subscribed. According to this, the Plaintiff shall pay the insurance life to the Defendant the amount calculated by multiplying the subscription amount (10 million won) and the payment rate by the amount (10 million won) in the event of a disability with less than 80% caused by the disease by August 3, 2049.

In addition, there is a "age pension with a disease of 50% or more" in the security matters covered by the Defendant at the time of the instant insurance contract, and according to this, the Plaintiff shall pay 60 million won monthly subscription amount (5 million won) for the five years when the Defendant suffers from a disease by the end of August 3, 2039.

B. The main contents of the Act on the Disability Pension with a disease of 50% or more included in the insurance contract of this case, the Act on the Special Conditions for Disability Pension, the Act on the Special Conditions for Disability after Disease, and the Disability Classification

Article 1 (Types of and Reasons for Payment of Insurance Money) of the Clause on the Special Disability Pension with 50% or more of the disease, where the disability payment rate provided for in the Disability Classification Table (attached Table 1; hereinafter the same shall apply) of the Insured (Persons Subject to Insurance) constitutes at least 50% of the disease determined during the insurance period, the Plaintiff is bound to pay the amount of insurance coverage of this Special Terms to the beneficiary (person who receives insurance money) with a disability pension with a disease of at least 50% for the first five years (if there is no designation of the beneficiary (person who receives insurance money) on the date of occurrence of the cause for payment of insurance money every five years for the first five years only once (in case of holidays and February 29).

Provided, That it is possible to make a lump sum payment at the request of a beneficiary (person who receives insurance money).