1. The Defendant (Counterclaim Plaintiff) paid KRW 38,641,963 to the Plaintiff (Counterclaim Defendant) and its related amount from June 11, 2014 to November 9, 2016.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Facts of recognition;

A. On March 31, 201, the Defendant increased the Defendant’s shares and allocated 22,000 shares in total to shareholders B, C, and D (hereinafter “the shareholders of this case”).

B. On April 12, 2013, the head of the Geumcheon District Tax Office sent a public notice to the Defendant on April 12, 2013, to the effect that as a result of a review of the comprehensive audit of the business affairs of the Gwangju Regional Tax Office on the allocation of the above stocks, there is an estimate to impose gift tax on the deemed donation amount of KRW 696,330,462, each of which is the deemed donation amount, and that the result is different from the property tax by the goldcheon Tax Office until April 18, 2013.

C. On April 22, 2013, the Plaintiff and the Defendant concluded the first service contract of the head of the Geumcheon Tax Office with the following contents as to the public notice, and the Defendant paid the Plaintiff the down payment of KRW 30 million and the value-added tax of KRW 3 million on April 23, 2013.

Article 1 (Scope of Services)

1. Affairs to reduce the gift taxes of KRW 696,30,462, respectively, of the aggregate amount of the gift taxes made by the shareholders of this case due to the increase of the company capital as a result of the audit and inspection of the gold and Tax Office capital;

2. Affairs, etc. of appeal related to the above. Article 2 (Period of Service Execution)

1. The execution period under Article 1 shall be from the date of performance of duties to the date of termination;

2. Where there exists a written agreement between the plaintiff and the defendant, the contract period as provided in paragraph (1) may be reduced or extended.

Article 3 (Service Fees)

1. The defendant shall pay 30% of the amount of reduced tax out of the defendant's estimated audit and cadastral share (640,000,000 won) as a result of the successful service under Article 1 to the plaintiff.

(Advance payment of down payment of KRW 30,000,000,000,000,000,000,000,000,000).2. The appeal is identical to the above paragraph 1, and the down payment is included.

The Plaintiff’s share allocation to the shareholders of the instant case pursuant to Stockholm options, not subject to gift tax due to capital increase, such as inequality.