1. The Plaintiff (Counterclaim Defendant)’s principal claim against the Defendant (Counterclaim Plaintiff) B and Defendant C, and the Defendant (Counterclaim Plaintiff)’s counterclaim.

A principal lawsuit or counterclaim shall be deemed to be a same.

1. Presumed factual basis

A. The Plaintiff is a corporation established for the purpose of processing and selling textile products.

Defendant B is the representative of “D” that conducts industrial equipment construction business, such as incineration boiler, and Defendant C is the husband of Defendant B.

B. On September 1, 2009, the Plaintiff entered into a construction contract (hereinafter “instant contract”) with Defendant B, setting the construction period from September 1, 2009 to November 30, 2009, with respect to the manufacture and installation of the Plaintiff’s RPF (Refuse Plause) incineration boiler (a boiler using waste vinyl as fuel; hereinafter “instant incineration boiler”).

C. From September 1, 2009 to January 22, 2010, the Plaintiff paid to Defendant B a total of KRW 325 million as the construction price under the instant contract.

The Plaintiff applied for permission to install the instant incineration boiler in Gyeonggi-do on March 2010, but was notified by Gyeonggi-do on April 16, 2010.

E. The Plaintiff filed an administrative litigation against the Governor of the Gyeonggi-do seeking the revocation of the revocation of the revocation of the revocation of the installation of air discharge facilities (U.S. District Court 2010Guhap6732), but lost on October 13, 2010.

However, the Plaintiff’s appeal was dismissed on July 15, 201 (Seoul High Court 2010Nu38990), and on December 8, 2011, the Plaintiff’s appeal was dismissed.

(Supreme Court Decision 201Du20253). [Grounds for recognition] A; Party 5, 6, 10, and 15 (including additional numbers); Party 1; and the purport of the whole pleadings

2. The parties' assertion

A. The Plaintiff’s assertion 1) Defendant B failed to complete the construction of the instant incineration boiler until the date of completion of the instant contract, and there was a defect in the already installed part. On February 6, 2013, Defendant C terminated the instant contract by sending content-certified mail to Defendant B. Defendant C as the actual operator of D.