CHICAGO - Two interrelated companies that were owned and operated by the son of a third company, which ceased doing business and was found liable for delinquent pension fund payments, may be substituted as judgment debtors for the third company as successors under the Employee Retirement Income Security Act, the Seventh Circuit U.S. Court of Appeals affirmed Jan. 9 (James T. Sullivan, et al. v. Running Waters Irrigation, Inc., et al., No. 13-1308, 7th Cir.; 2014 U.S. App. LEXIS 482).