1 . Poole and Trammell denied that Poole made this statement. R2-33, Exh. 16 at 8(28); Exh. 15 at 16 (59-60). 2 . Although the district court never specifically mentioned Phillips’s race discrimination claim under § 1981, it implicitly rejected it on this basis as well because the analysis for a § 1981 claim is the same as for Title VII race discrimination claims, Crawford v. Western Elec. Co., 745 F.2d 1373, 1376 (11th Cir. 1984), and it granted summary judgment as to "all” of Phillips’s claims. Rl-41. 3 . Even though the suggested comparator here, Yonkman, was fewer than 10 years younger than Phillips, we have held that as few as three years difference in age can satisfy the “substantially younger” requirement. See Carter v. DecisionOne Corp., 122 F.3d 997, 1003-04 (11th Cir. 1997) (<HOLDING>); see also Damon, 196 F.3d at 1360. 4 . As
holding that the fourth prong of a prima facie age discrimination case was satisfied where plaintiff was replaced by two individuals  one who was four years younger than plaintiff and the other who was ten years younger holding that being replaced by someone outside the protected class is not a proper element of the fourth prong because replacement by a substantially younger employee is a far more reliable indicator of age discrimination holding that plaintiff aged 42 who was replaced by employee aged 39 met the substantially younger replacement requirement under adea holding when an employee was temporarily replaced by a person who was 10 years younger and permanently replaced by a person four years younger this was sufficient for the prima facie case holding that when a 56year old employee was replaced by a 40year old employee this qualified as someone substantially younger for the purposes of establishing a prima facie case