1. The Plaintiff:

A. As to Defendant A, B, and C’s joint and several KRW 472,681,49 and KRW 117,920,000, respectively.

1. Indication of claim;

A. Defendant A Co., Ltd. (hereinafter “Defendant A”) concluded a performance guarantee insurance agreement (contract) between Defendant A Co., Ltd. and Seoul Guarantee Insurance Co., Ltd. (hereinafter “Defendant A”) with the Seoul Guarantee Insurance Co., Ltd. (former trade name: Korea Guarantee Insurance Co., Ltd.; hereinafter “Nonindicted Co., Ltd.”) to guarantee the obligation of the contract deposit related to the steel plant construction for the newity of Defendant A Co., Ltd. (hereinafter “instant 1 agreement”), and issued the guaranty insurance policy. At the time of the instant 1 agreement, Defendant B and C guaranteed the obligation of Defendant A to be borne by the Nonparty Co., Ltd. due to the said agreement.

The content of the First Agreement is as follows.

(B) Defendant A failed to perform the obligation to pay the above contract deposit from July 10, 1996 to June 30, 1998, Defendant A paid KRW 117,920,000 as insurance money to New Construction Co., Ltd., Ltd. (contract) the insurance period of the insured subject to insurance (contract). The non-party A paid KRW 117,920,000 to New Construction Co., Ltd., on June 12, 1998, the non-party A paid KRW 117,920,00 as insurance money (Advance payment) between the non-party Company A and the non-party Company, and the Defendant A performed guarantee insurance agreement (hereinafter “instant agreement”).

2) Defendant B, C, and C at the time of the instant 2 agreement (hereinafter “Defendant 1”)

2) Defendant LLC Co., Ltd. (hereinafter “Defendant LLC”)

In accordance with the above agreement, Defendant A guaranteed the obligation to be borne by Nonparty A to the non-party company.

The content of the second agreement is as follows.

Insurance coverage period of the insured for each insurance item.