is a logical relationship between the claim in suit and the counterclaim.” Genentech, Inc. v. Regents of the Univ. of California, 143 F.3d 1446, 1456 (Fed.Cir.1998). “In making this determination, which invokes judicial discretion, the court may give weight to the advantages of consolidation, efficiency, and expedition....” Id. “[Claim preclusion applies] even though the claimant is prepared in a second action to present different evidence or legal theories to support his claim or seeks different remedies.” Heacock, 402 Mass. at 23, 520 N.E.2d 151. Courts have held claims to be compulsory counterclaims to earlier actions, and thus precluded, even though the later actions involved a different body of law and different remedies. See, e.g., In re Iannochino, 242 F.3d 36, 38 (1st Cir.2001) (<HOLDING>); Genentech, 143 F.3d at 1456 (holding claim
holding that the district court had bankruptcy jurisdiction over a professional malpractice action filed by a title 11 debtor against the law firm that represented him in his bankruptcy case under section 1334b because the malpractice claim arose in the bankruptcy case holding that a corporate chapter 7 debt ors malpractice claim against its bankruptcy attorney was related to its bankruptcy case holding that suit for professional malpractice was compulsory counterclaim to earlier award of fees in bankruptcy to debtors attorney holding professional malpractice claim not contractual holding because an award of attorney fees is discretionary court may consider attorney fees in relation to the underlying equities in the case