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(Provisional Translation)
October 23, 2015
Securities and Exchange Surveillance Commission

Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading of Shares of GameOn Co., Ltd. by Individual Investor Residing Abroad


1. Contents of the Recommendation

The Securities and Exchange Surveillance Commission, today, made a recommendation to the Prime Minister and the Commissioner of the Financial Services Agency that an administrative monetary penalty payment order be issued in regard to insider trading of the shares of GameOn Co., Ltd. (“GameOn”) by an individual investor residing abroad, an employee of a party in negotiation to conclude a contract with a tender offeror, pursuant to Article 20(1) of the Act for Establishment of the Financial Services Agency. This recommendation is based on the findings of the investigation into the insider trading, whereby the following violations of laws and ordinances were identified.

2. Summary of the Findings Regarding Violations of the Laws and Ordinances

The person subject to the administrative monetary penalty payment order (residing in Korea), in regard to negotiation to conclude a contract with Neowiz Games Corporation (“Neowiz”), with the knowledge of a fact concerning launch of a tender offer, which the responsible body for making decisions of Neowiz had decided to launch a tender offer of the shares of GameOn, from September 14, 2011 to October 27, 2011, which period is prior to the publication of the above fact, purchased a total of 137 shares of GameOn for 8,189,600 yen on the person’s own accounts.

The actions mentioned above conducted by the person subject to the administrative monetary penalty payment order were recognized as actions "in violation of the provisions of Article 167(1) or (3) in effecting a Purchase, etc. prescribed in Article 167(1)" as stipulated under Article 175(2) of the Financial Instruments and Exchange Act ("FIEA").

3. Calculation of the Amount of the Administrative Monetary Penalty

Pursuant to the FIEA, the amount of the administrative monetary penalty applicable to the above violations is 3,860,000 yen.

Details of the calculation are presented in the Attachment.

4. Others

We appreciate assistance of the Financial Service Commission and the Financial Supervisory Service in Korea in this matter.

Attachment

● Method of Calculation of the Amount of the Administrative Monetary Penalty

Pursuant to Article 175(2) of the FIEA, the amount of the administrative monetary penalty shall be the amount obtained by deducting the amount specified in item (b) below from the amount specified in item (a) below:

(a)The amount obtained by multiplying the highest price in the two weeks after the publication of the fact concerning launch of the tender offer by the volume of the purchase, etc. of securities

(b)The amount obtained by multiplying the price at which the person effected the purchase, etc. by the volume of the purchase, etc. of securities

As the highest price of GameOn share in the two weeks after the publication of the fact concerning launch of the tender offer was 88,000 yen, the amount of the administrative monetary penalty is calculated as below:

(88,000 yen x 137 shares) - (Value pertaining to purchase of 8,189,600 yen) (*)

= 3,866,400 yen

Pursuant to Article 176(2) of the FIEA, the amount of the administrative monetary penalty shall be 3,860,000 yen, which is rounded down to the nearest ten-thousand.

(*)Value pertaining to purchase is calculated as below:

(57,200 yen x 1 share + 57,500 yen x 5 shares + 57,600 yen x 1 share + 57,700 yen x 1 share + 57,800 yen x 6 shares + 57,900 yen x 8 shares + 58,000 yen x 10 shares + 58,100 yen x 2 shares + 58,300 yen x 1 share + 58,400 yen x 5 shares + 58,500 yen x 7 shares + 58,600 yen x 3 shares + 58,900 yen x 3 shares + 59,000 yen x 7 shares + 59,600 yen x 1 share + 59,700 yen x 1 share + 59,800 yen x 1 share + 59,900 yen x 4 shares + 60,000 yen x 2 shares + 60,300 yen x 7 shares + 60,500 yen x 12 shares + 60,600 yen x 1 share + 60,700 yen x 1 share + 60,800 yen x 5 shares + 60,900 yen x 3 shares + 61,000 yen x 11 shares + 61,200 yen x 1 share + 61,300 yen x 3 shares + 61,500 yen x 6 shares + 61,700 yen x 3 shares + 61,800 yen x 2 shares + 62,000 yen x 5 shares + 62,100 yen x 2 shares + 62,300 yen x 1 share + 62,400 yen x 1 share + 62,500 yen x 1 share + 62,700 yen x 3 shares)

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