I think the article says he added additional claims to the second lawsuit, but they all flow from the same set of facts/transaction, it should be Res Judicata.

I think the article says he added additional claims to the second lawsuit, but they all flow from the same set of facts/transaction, it should be Res Judicata. Odds are Defendant can Vacate the Judgment on: 1. Improper Service of Process; and/or 2. Defenses on the Merits, including, Res Judicata. Assuming the Defendant can establish Plaintiff knowingly obtained default based on improper service, and show Plaintiff knew or should have known the claims weren't supported by fact or law the Defense should recoup their fees on the Motion to Vacate Default Judgment through sanctions.