1. On 29 May 2003, ICA Biotechnological - Pharmaceutical JSC and Ahn-Gook Pharmaceutical Co., Ltd. (Korea) entered into License Agreement for TOBICOM Manufacturing in Vietnam (Contract No. AGIC-030529), under which, ICA Biotechnological - Pharmaceutical JSC is licensed to manufacture pharmaceutical products bearing the brand TOBICOM in Vietnam. On 24 July 2007, the parties mutually entered into Appendix A on Amendment of Contract AGIC-030529, under which ICA Biotechnological - Pharmaceutical JSC is entitled to have perpetual ownership right over and in connection with the brand TOBICOM. Contract No. AGIC-030529 and its Appendix A were registered with the Vietnam Administration of Vietnam.

2. On 27 May 2010, Ahn-Gook Pharmaceutical Co., Ltd. appointed new personnel, and due to the lack by its new personnel of Appendix A of Contract No. AGIC-030529, bilaterally proposed the end of Contract No. AGIC-030529. Such bilateral proposal of Ahn-Gook Pharmaceutical Co., Ltd. to end Contract AGIC-030529 violates Article 13.5 of Contract No. AGIC-030529. Therefore, Ahn-Gook Pharmaceutical Co., Ltd. is obliged to compensate 30% of the total license fee being 977,000 USD and all other losses and damages to ICA Biotechnological - Pharmaceutical JSC as follows:
   a) Compensation of 20% of the total accumulated value of imported TOBICOM products for duration of nine (9) years from 1995 to 2003, in the amount of 1,500,000 USD in accordance with Contract No. 1054 signed on 1 January 1999 between ICA Biotechnological - Pharmaceutical JSC and Ahn-Gook Pharmaceutical Co., Ltd.
   b) Compensation of 100% advertisement expenses to ICA Biotechnological - Pharmaceutical JSC, which was actually spent by it for advertisement of products bearing the brand TOBICOM within a period of fifteen (15) years from 1995 to 2010 in the amount of 6,500,000 USD in accordance with vouchers and documents with Television stations and Press agencies in Vietnam.

The total accrued amount that Ahn-Gook Pharmaceutical Co., Ltd. (Korea) has to compensate ICA Biotechnological - Pharmaceutical JSC as of 30 June 2010 under Article 13.5 of Contract No. AGIC-030529 is 9,000,000 USD, on the ground of Ahn-Gook’s violation to the exclusive right agreement.

Violation committed by Ahn-Gook Pharmaceutical Co., Ltd. in granting any license to other companies not under the exclusive right contract and its annexes signed between ICA Biotechnological - Pharmaceutical JSC and Ahn-Gook Pharmaceutical Co., Ltd. (on 1 January 1999, 29 May 2003 and 24 July 2007 as mentioned above) constitutes a serious trade fraud. ICA Biotechnological - Pharmaceutical JSC will take appropriate legal actions to protect its legitimate rights and commercial interest as well as those of Vietnamese domestic enterprises.

ICA Biotechnological - Pharmaceutical JSC