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This paper compares secondary predication constructions (including small clause complements, resultatives, and/or depictives) in English and Korean and argues that these two typologically different languages employ different modes of satisfying the Case Filter (Chomsky 1981) with regard to the Case of the subjects of secondary predication constructions. More specifically, we argue that the subject of the secondary predicate in English is Accusative Case-marked by the higher governing verb, while that in Korean is Nominative Case-marked by default. Evidence for default Nominative Case will be provided from Korean and other languages.