What is the primary right at issue in a second action brought by appellant against a corporation for breach of contract?

In the previous action, the harm suffered by appellant was the breach of his contract, and the wrong committed was the corporation's failure to comply with the contract. The fact appellant included various theories of recovery (i.e., breach of contract, conversion, common counts, declaratory relief) does not change the primary right at issue in the action. As the court observed in Eichman v. Fotomat Corp. (1983) 147 Cal.App.3d 1170, 197 Cal.Rptr. 612, "if two actions involve the same injury to the plaintiff and the same wrong by the defendant then the same primary right is at stake even if in the second suit the plaintiff pleads different theories of recovery, seeks different forms of relief and/or adds new facts supporting recovery." (Eichman v. Fotomat Corp., supra, 147 Cal.App.3d at pp. 1174-1175, 197 Cal.Rptr. 612, internal quotations omitted.)