1. The Defendant-Counterclaim Plaintiff Co., Ltd. shall reproduce, transmit, distribute the three computer programs listed in the attached Table 1 list.

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

1. Basic facts

A. The Plaintiff developed each source code listed in the attached Table 2 (hereinafter “Plaintiff’s respective source code”) as a company that developed and sells the quality inspection system through the measurement and analysis of noise and vibration.

B. Defendant B served as a researcher of the Plaintiff Company from May 2, 2003 to February 29, 2008, and was appointed as a representative director after establishing the Defendant Company around January 2, 2008, which was around the time of retirement of the Plaintiff Company.

C. From February 10, 2002, E served as a researcher of the Plaintiff Company, around September 2008, and entered the Defendant Company around 2009 after withdrawal of the Plaintiff Company.

The Defendant Company developed each computer program listed in the separate sheet No. 1 list (hereinafter referred to as “the Defendant’s program 1 through No. 3,” hereinafter referred to as “the Defendant’s respective program”) and the Defendants’ program No. 1 program as set out in the separate sheet No. 3 attached hereto (hereinafter referred to as “the Defendant’s each program”) and the Defendant’s each product collectively referred to as “the Defendant’s each product” in the separate list No. 1 through No. 3 attached hereto.

In addition, the Defendants’ 2 program was set up on the Defendants’ 2 products, and the Defendants’ 3 program was sold after the Defendants’ 3 program was set up on the Defendants’ 3 products, respectively. [Grounds for recognition] The Defendants’ 1, 5, 6, 13, and 49 Certificate (which may include each number; hereinafter the same shall apply).

each entry, the purport of the whole pleading

2. Determination as to the claim on the principal lawsuit

A. 1) The Plaintiff’s trade secret infringement (1) Plaintiff’s respective source code is the Plaintiff’s trade secret.

(2) At the time of the retirement of the Plaintiff Company, Defendant B leaked the Plaintiff’s respective source code, and Defendant Company obtained the Plaintiff’s trade secret by unlawful means, such as obtaining the Plaintiff’s respective source code by entering E around July 2008.

(3) The Defendant Company developed each product of the Defendants using the Plaintiff’s respective source code.