1. The Plaintiff’s damage liability against the Defendant based on the supply contract of materials between the Plaintiff and the Defendant on September 29, 201.

1. Basic facts

A. On September 29, 201, the Plaintiff entered into a material supply contract and a guarantee insurance contract with the Defendant, and as a result, from among A’s engineering works contracted by Samsung Engineering Co., Ltd. (hereinafter “instant construction”).

In relation to the contract amount of KRW 1110,1330,000 (i.e., value of KRW 1.10,030,000 won value-added tax of KRW 11.10,000,000), the delivery period from September 29, 201 to December 28, 2011; 10% of the contract deposit; 30% of the advance payment performance guarantee; and 10% of the contract for the supply of substitute materials (hereinafter “instant supply contract”).

(2) On October 11, 201, the Plaintiff entered into the instant supply contract with the Seoul Guarantee Insurance Co., Ltd. (hereinafter “Seoul Guarantee Insurance Co., Ltd.”) as the insured regarding the instant supply contract, which is a main contract, and issued each insurance policy to the Defendant, respectively. The Plaintiff entered into a contract with the Seoul Guarantee Insurance Co., Ltd. (hereinafter “Seoul Guarantee Insurance Co., Ltd.”).

B. (1) On October 13, 2011, the Defendant paid KRW 298,181,819 to the Plaintiff advance payment, and thereafter, paid KRW 414,958,835 to the Plaintiff more than 11 times from February 1, 2012, thereby paying KRW 713,140,654 in total as material price. (2) According to the instant supply contract, the Plaintiff should import and clearance import of tin materials manufactured by a third party in the local area, such as Indonesia, China, and the Philippines, and supply them to the Defendant’s domestic construction site.

The Plaintiff, as stipulated in the instant supply contract, shall be deemed to have existed from December 201 to January 20, 201, as stipulated in the instant supply contract.