Fund v. Artistic Furniture of Pontiac, 920 F.2d 1323, 1325 (7th Cir.1990) (citing Travis v. Harris Corp., 565 F.2d 443, 446 (7th Cir.1977)). Courts have recognized four exceptions to this general rule. The corporation buying the assets is liable as a successor when (1) the purchaser expressly or impliedly agrees to assume the liabilities of the selling corporation; (2) the transaction is a de facto merger or consolidation; (3) the purchaser is a “mere continuation” of the seller; or (4) the transaction is an effort to fraudulently escape liability. Id. B. “Liberalized” Successor Liability under Employment Statutes Successor liability for employment discrimination judgments is broader than the common law exceptions. Wheeler v. Snyder Buick, Inc., 794 F.2d 1228, 1237 (7th Cir.1986) (<HOLDING>). Accord: Upholsterers’, 920 F.2d at 1326
holding employees under age discrimination in employment acts adea parallel retaliation provision includes former employees as long as the alleged discrimination is related to or arises out of the employment relationship holding that congressional intent to eliminate employment discrimination justified the liberalization of common law successorship rules in favor of victims of discrimination in employment holding that a claim for discrimination in private employment is not preempted by title vii holding that evidence of egregiousness is required for punitive damages since otherwise every employment discrimination claim could include a punitive damage award because every employment discrimination plaintiff must demonstrate an intentional unlawful discrimination holding that disparate impact analysis may be applied to subjective employment practices in employment discrimination actions