Where a judgment is based on estoppel by representation (arising from a party's pleadings and affidavits), that judgment is not inconsistent with a later judgment based on the truth against a different party. Proceedings alleging that fraud induced the conduct creating the estoppel enforced in the earlier proceedings are not barred by Anshun estoppel and are not an abuse of process, because the plaintiff did not have a full opportunity to litigate the issue in the earlier proceedings. An action claiming damages for loss caused by an adverse judgment resulting from the defendant's fraud is not a collateral attack on that judgment.
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