Does the phrase 'same transaction, occurrence or series of transactions or occurrences' require a degree of factual commonality?

"The Ninth Circuit has interpreted the phrase 'same transaction, occurrence, or series of transactions or occurrences' to require a degree of factual commonality underlying the claims." Bravado Int'l Grp. Merch. Servs. v. Cha, No. CV 09-9066 PSG (CWx), 2010 WL 2650432, at *4 (N.D. Cal. June 30, 2010). The rule simply requires "related activities" and "similarity in the factual background of a claim." Jacques v. Hyatt Corp., No. C 11-05364 WHA, 2012 WL 3010969, at *3 (N.D. Cal. July 23, 2012) (citing Bravado, 2010 WL 2650432, at *4).