Pursuant to the Supreme Court’s judgment on August 10, 2016, the Company Act does not expressly provide the method for share transfer involving shares in a company limited by shares. The court held that share transfers involving shares without certificates shall nevertheless be effective upon the parties’ expression of their mutual agreement and promises. This holding is based on the principle that share certificates are securities evidencing the shares denoted thereon, and that shares are not created by the issuance of share certificates. The issuance of share certificate by a company limited by shares, whether to fulfill its legal obligation or as its own choice, shall not affect the existence of the shares. In the absence of legal restrictions or prohibitions on share transfer, shareholders may transfer share(s) upon the parties’ expression of their mutual agreement and promises. A company’s failuire to issue share certificates, whether in violation of a requirement to do so or otherwise, shall not pose any limitation on a shareholder’s freedom to transfer shares, as provided by the Company Act.