In DKN Holdings LLC v. Wade Faerber (2015) 61 Cal.4th 813, DKN was a landlord that sued Caputo, one of several tenants that were jointly and severally liable on a lease, and secured a final judgment on the merits against him. It then sued the other two tenants, who had been named but were never served in the first action. One of those tenants, Faerber, urged that the claim against him was barred because DKN had successfully sued Caputo on the claim. The court rejected that argument, explaining, "Claim preclusion does not bar DKN from suing Faerber because Faerber is not 'the same party' who defended the cause of action in the first suit, nor was he in privity with Caputo based on their business partnership or cosigner status." (61 Cal.4th at p. 825.) The California Supreme Court distinguished collateral estoppel, or issue preclusion, from res judicata, or claim preclusion. Claim preclusion acts to bar relitigation of the same cause of action in a second suit between the same parties or their privies. (Id. at p. 824.) "Issue preclusion prohibits the relitigation of issues argued and decided in a previous case, even if the second suit raises different causes of action . . . the prior judgment conclusively resolves an issue actually litigated and determined in the first action." (Id. at p. 824.) In accordance with due process, issue preclusion may be asserted only against a party to the first lawsuit or one in privity with a party. (Ibid.) The California Supreme Court explained in the term " 'res judicata' " is imprecise, as it has been used "as an umbrella term encompassing both claim preclusion and issue preclusion" and as a synonym for claim preclusion. This inconsistency has "caused some confusion." (Id. at p. 823.) "To avoid future confusion" between the two types of preclusion, which "have different requirements," the court endorsed the use of the terms " 'claim preclusion' " and " 'issue preclusion.' " (Id. at p. 824.)