The definition of "claim" in the Bankruptcy Code is very broad, and includes a right to payment, whether or not such right is, inter alia, unliquidated, contingent, or unsecured. 11 U.S.C. § 101(5). See In re Eyke, 246 B.R. 550, 558 (Bankr. W.D. Mich. 2000) (recoupment permitted against future attorneys' fees to be incurred). Additionally, recoupment is an equitable doctrine, and courts have considered the standard for recoupment as requiring "that there be such a close, necessary relationship between the events that gave rise to the debtor's postpetition claim and the events that gave rise to the creditor's prepetition claim that the amount of the former cannot fairly be determined without accounting for the latter." In re St. Francis Physicians Network, Inc., 213 B.R. 710, 719 (Bankr. N.D. Ill. 1997). Courts have also noted that "recoupment is justified in single contract bankruptcy cases, since there is but one recovery due on contract and that recovery must be determined by taking into account mutual benefits and obligations of the contract.

{¶ 37} Besides being an equitable defense under New York common law, recoupment also "has long been utilized in the bankruptcy context." In re Eyke (Bkrtcy.W.D.Mich., 2000), 246 B.R. 550, 557, citing In re Gasmark Ltd. (C.A.5, 1999), 193 F.3d 371, 374, citing In re U.S. Abatement Corp (C.A.5, 1996), 79 F.3d 393, 398. Here, because Buckeye Steel's seeking of bankruptcy protection and the bankruptcy court's later approval of Columbus Steel Castings' purchase of the assets of Buckeye Steel and certain of its affiliates are relevant factual issues, we also shall consider bankruptcy principles in addition to New York law to determine whether, as TTA claims, the trial court erred when it in effect granted summary judgment in favor of Columbus Steel Castings by preventing TTA from asserting recoupment as an affirmative defense.