1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The reasoning of the judgment of the court of first instance is as follows, except for dismissal or addition and deletion of some contents, and thus, it is identical to the reasoning of the judgment of the court of first instance. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

In addition, there is a strong doubt that the Plaintiff did not control or manage the overall operation of the O through K, K, and the employees of the subsidiaries of this case, “I see that there was a strong doubt that the Plaintiff did not control or manage the overall operation of the K, K, and the subsidiaries of this case.”

The following "Nos. 48, 64, 91" in Part 17 of the Judgment of the first instance shall be added to "(including a number)."

Article 19 of the first instance court Decision 19 provides various evidences, such as the State and the State and F, and H’s stock title trust agreement between Z and H, and the statement of the Hong Kong KRG’s external auditor. According to such evidence, Z as “The possibility that Z is a beneficial shareholder of O cannot be ruled out as the title trustor of the instant shares.”

The following shall be added to the third activity following the judgment of the first instance.

h) The Defendant asserted that the title truster of the instant shares is the Plaintiff on the ground of the circumstances described in the foregoing 2). However, even according to such circumstances, it is insufficient to recognize that the Plaintiff merely participated in the management and administration of theO or the instant subsidiaries in the position that is not the shareholder of the Plaintiff, as alleged by the Plaintiff, or that K, other than the Plaintiff, could not exclude the possibility of being a title truster of the instant shares, is a beneficial shareholder of O solely on the ground that such circumstance is insufficient to recognize that the Plaintiff was a beneficial shareholder of O. The part of the judgment of the first instance court from the “Determination on the Grounds for Main Disposition.”

Judgment of the first instance.