1. Defendant A Promotion Committee: (a) 2,400,000,000 won for the Plaintiff and the period from May 16, 2012 to December 31, 2012.

1. Basic facts

A. On July 1, 2010, the Plaintiff (hereinafter “STX”) planned to reclaim public waters in Masan City and implement a project to create a general industrial complex (hereinafter “instant project”) by reclaiming D public waters in Masan City. Accordingly, the MTX Heavy Industries Co., Ltd. (hereinafter “STX”) and the project implementer, the MTX Co., Ltd. (hereinafter “STX”) entered into the Convention on the Reclamation of Public Waters on June 7, 2007.

Article 1 (Consent of Residents for General Industrial Complexes) ① The Plaintiff and STX shall create the G reclaimed land adjacent to the G reclaimed land (hereinafter referred to as “D, etc.”) that has been changed to the industrial area in accordance with the 230,978 square meters and 2020 Msan Basic Urban Planning in Masan-si, MTX as a general industrial complex, and the Defendant Promotion Committee shall submit it to MTX with the consent of the entire residents in an objective manner.

② The Defendant Promotion Committee shall submit the written consent referred to in paragraph (1) to SX by May 30, 2008. If the Defendant Promotion Committee fails to submit the written consent within the time limit, SX may not perform the terms of this Convention, and SX shall not bear any responsibility for the non-performance of the terms of this Convention.

Article 2 (E Village Development Fund) ① The Plaintiff and STX jointly create a total of 8 billion won of the E Village Development Fund after the conclusion of this Agreement and the submission of written consent from residents, and 4 billion won shall be deposited under the name of the Plaintiff, Defendant Promotion Committee, and STX at the financial institution designated by the Defendant Promotion Committee within 10 days from the date of the conclusion of the Convention, and the remainder of 4 billion won shall be deposited within 2 months from the date of

(2) The operation of the Village Development Fund shall be delegated to the defendant promotion committee.

Article 5 (Effectuation of this Convention) The provisions of this Convention shall become effective upon the conclusion of the Convention.

However, if the defendant promotion committee does not submit the entire written consent of the E residents to the STX, all of the written consent shall be effective.