Notice2026-09147
United States et al. v. RealPage, Inc. et al. Response to Public Comments
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
May 8, 2026
Issuing agencies
Justice DepartmentAntitrust Division
Full Text
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<title>Federal Register, Volume 91 Issue 89 (Friday, May 8, 2026)</title>
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[Federal Register Volume 91, Number 89 (Friday, May 8, 2026)]
[Notices]
[Pages 25373-25381]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-09147]
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DEPARTMENT OF JUSTICE
Antitrust Division
United States et al. v. RealPage, Inc. et al. Response to Public
Comments
Notice is hereby given pursuant to the Antitrust Procedures and
Penalties Act, 15 U.S.C. 16(b)-(h), that the Response of the United
States to Public Comment on the Proposed Final Judgment in United
States of America et al. v. RealPage et al., Civil Action No. 24-cv-
00710- WLO-JLW, in regards to Defendant RealPage, Inc., has been filed
in the United States District Court for the Middle District of North
Carolina, together with the response of the United States to the
comments.
Copies of the public comment and the United States' Response are
available for inspection on the Antitrust Division's website at <a href="http://www.justice.gov/atr">http://www.justice.gov/atr</a>.
Suzanne Morris,
Deputy Director Civil Enforcement Operations, Antitrust Division.
In the United States District Court for the Middle District of North
Carolina
United States of America, et al., Plaintiffs, vs. Realpage,
Inc., et al., Defendants.
1:24-cv-00710-WLO-JGM
Response of Plaintiff United States to Public Comments on the Proposed
Final Judgment
Pursuant to the requirements of the Antitrust Procedures and
Penalties Act (the ``APPA'' or ``Tunney Act''), 15 U.S.C. 16(b)-(h),
the United States submits this response to the eight public comments
received regarding the proposed Final Judgment as to Defendant
RealPage, Inc. (Doc. 159-1).\1\
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\1\ The United States has redacted personally identifiable
information from the comments. If the Court requests unredacted
versions, the United States will provide unredacted comments under
seal.
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After careful consideration of the submitted comments, the United
States continues to believe that the proposed Final Judgment will
provide an effective and appropriate remedy for the antitrust
violations alleged in the Complaint.\2\
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\2\ The Complaint includes a number of claims asserted by co-
Plaintiff States. This Response, like other filings that the United
States has made under the Tunney Act, focuses only on the United
States' claims in the Complaint, which are the only claims that
would be resolved by the proposed Final Judgment, if entered.
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After this Response has been published in the Federal Register,
pursuant to 15 U.S.C 16(d), the United States will move the Court to
enter the proposed Final Judgment. On March 4, 2026 the Court granted
the United States' motion to allow the United States to publish the
public comments on the Antitrust Division's website due to the expense
of publishing the comments in the Federal Register and the public
accessibility of the Division's website. (Doc. 174.) These comments can
be accessed at <a href="http://www.justice.gov/atr">www.justice.gov/atr</a>.
[[Page 25374]]
I. Procedural History
On August 23, 2024, the United States, along with several States
(``Plaintiffs''), filed a civil antitrust Complaint against RealPage,
Inc. (``RealPage''). (Doc. 1.) On January 7, 2025, Plaintiffs amended
their Complaint (the ``Complaint'') to add six property management
companies (referred to herein as ``landlords'') as Defendants. (Doc.
47.) The Complaint alleges that RealPage violated Section 1 of the
Sherman Act, 15 U.S.C. 1, by unlawfully agreeing to share and use
landlords' competitively sensitive information and agreeing to use
RealPage's software to align pricing among competing landlords. The
Complaint also alleges that RealPage violated Section 2 of the Sherman
Act, 15 U.S.C. 2, by monopolizing or attempting to monopolize the
commercial revenue management software market for conventional
multifamily rental housing by preventing other software providers from
effectively competing with products that do not harm the competitive
process.
On November 24, 2025, the United States filed a proposed Final
Judgment (Doc. 159-1) as to RealPage, which is designed to remedy the
loss of competition alleged in the Complaint due to RealPage's conduct,
and a Stipulation and Proposed Order (Doc. 159), in which RealPage
consented to entry of the proposed Final Judgment after compliance with
the requirements of the Tunney Act. On November 24, 2025, the United
States filed a Competitive Impact Statement describing the proposed
Final Judgment as to RealPage. (Doc. 160.) On March 26, 2026, the Court
entered the Stipulation and Proposed Order. (Doc. 182.)
The United States arranged for the publication of the Complaint,
proposed Final Judgment, and Competitive Impact Statement in the
Federal Register on December 5, 2025, see 15 U.S.C. 16(b)-(c); 90 FR
56,286 (Dec. 5, 2025), and caused notice regarding the same, together
with directions for the submission of written comments relating to the
proposed Final Judgment, to be published in The Washington Post from
December 10-16, 2025 and in the Greensboro News and Record from
December 10-15, 2025 and December 16-17, 2025. The 60-day period for
public comment has now ended. The United States received eight comments
in response, which are described below and attached as Exhibit 1
hereto.
II. The Complaint and the Proposed Final Judgment
As explained in the Competitive Impact Statement (Doc. 160),
RealPage licenses three revenue management products to property
management companies and property owners (collectively, ``landlords'').
These software products are AI Revenue Management (``AIRM''),
YieldStar, and Lease Rent Options (``LRO''). RealPage's revenue
management products are used by landlords to determine how to price
floor plans and units in conventional multifamily rental housing, i.e.,
multiunit apartments that they manage and lease.
The Complaint alleges that RealPage, along with six landlords,
violated Section 1 of the Sherman Act, 15 U.S.C. 1, by unlawfully
agreeing to share and use competitively sensitive information for the
properties that each landlord manages and leases. RealPage uses
nonpublic, competitively sensitive data to train its algorithmic models
(``models'') that AIRM leverages and to provide floor plan price
recommendations and unit-level pricing to landlords when they are
running AIRM or YieldStar. The sharing and use of nonpublic,
competitively sensitive information harms or is likely to harm the
competitive process, renters, and prospective renters.
The Complaint further alleges that RealPage and the landlords that
use AIRM and YieldStar violated Section 1 of the Sherman Act, 15 U.S.C.
1, by unlawfully agreeing to use RealPage's software to align pricing
among competing landlords. RealPage entered into individual agreements
with landlords to use AIRM or YieldStar. By agreeing to use AIRM or
YieldStar as each has been designed by RealPage, competing landlords
align their pricing processes, strategies, and pricing responses, e.g.,
how they go about setting rents, pricing amenities, and managing
occupancy levels in local rental markets. As alleged in the Complaint,
both RealPage and landlords knew that the software was designed to
align pricing. They used the phrase ``a rising tide rises [sic] all
ships'' to explain that AIRM and YieldStar would move prices in a
``similar manner'' to how the top and bottom of the market moved. (See
Am. Compl. ] 33.) Collectively, these agreements harm the competitive
process and actual and prospective renters.
Finally, the Complaint alleges that RealPage violated Section 2 of
the Sherman Act, 15 U.S.C. 2, by monopolizing or attempting to
monopolize the commercial revenue management software market for
conventional multifamily rental housing. Through its licensing
agreements with landlords that use its software products, RealPage has
amassed a massive reservoir of competitively sensitive data from
competing landlords. RealPage has ensured that other providers of
revenue management products cannot compete on the merits unless they
enter into similar agreements with landlords, thereby obstructing them
from competing with products that do not harm the competitive process.
The proposed Final Judgment imposes a number of requirements and
restrictions on RealPage that address the United States' concerns
regarding RealPage's anticompetitive conduct alleged in the Complaint.
First, the proposed Final Judgment imposes restrictions on how RealPage
can use competitively sensitive data from landlords. The proposed Final
Judgment identifies two discrete phases of how RealPage's revenue
management products operate: runtime operation and model training.
Runtime operation is a landlord's use of the software to provide
pricing recommendations and prices for the specific floor plans and
units in a particular rental property. Model training is any process of
analyzing data to create a model or algorithm, including the models
that RealPage uses to predict supply and demand, which is then used in
the runtime operation. Subject to limited exceptions, RealPage will not
be allowed to use nonpublic data from competing properties in runtime
operation. In training the models, RealPage will be limited to using
backward-looking data that has been aged at least 12 months and is not
from active leases, i.e., a unit with a rental agreement that is in
effect.
Second, the proposed Final Judgment restricts RealPage's ability to
source nonpublic information from and share nonpublic information among
landlords. The proposed Final Judgment imposes significant limitations
on RealPage's ability to use, share, publish, disclose, or provide
competitors' nonpublic data to a landlord, including through RealPage's
revenue management products or its pricing advisors. Relatedly,
RealPage must not conduct any market surveys (the collection of
potentially competitively sensitive nonpublic data through call
arounds, emails, or other methods) for use in its revenue management
products or to recommend a rental price or occupancy level during the
term of the proposed Final Judgment. Finally, RealPage must not discuss
with or facilitate discussions among landlords
[[Page 25375]]
about market analyses or trends based on nonpublic data, or about
pricing strategies.
Third, the proposed Final Judgement limits RealPage's ability to
use models trained using nonpublic, competitively sensitive information
to determine price and supply below a certain geographic level.
RealPage may not train its AI Demand, AI Supply I, and AI Supply II
models with a geographic variable narrower than a state.\3\ RealPage
may not use nonpublic, competitively sensitive data to train any future
models with a geographic variable narrower than the nation.
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\3\ As explained in the Competitive Impact Statement (Doc. 160),
RealPage relies on three models in AIRM: AI Demand, AI Supply I, and
AI Supply II. AI Demand predicts the likelihood that a prospective
tenant will apply for a unit at a specific property. The AI Supply
models predict the likelihood that an expiring lease will be renewed
rather than terminated. AI Supply I predicts the likelihood of
renewal before a renewal rent offer has been approved by the
landlord, while AI Supply II predicts the likelihood of renewal
using an approved renewal rent offer. Each of RealPage's models is
one of multiple inputs used to determine, during runtime operation,
the supply and demand at a particular property.
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Fourth, RealPage must modify or otherwise ensure that certain
software features are designed so that they no longer raise competitive
concerns that underlie the allegations in the Complaint. For example,
RealPage may not prohibit or impede a landlord's ability to reject or
override a recommended price. Similarly, any software feature that
automatically accepts recommended prices must require that a landlord
individually set the parameters regarding that acceptance. Any limit on
price increases and decreases must be symmetrical, and a landlord must
individually determine the limits.
Fifth, RealPage must adopt and comply with a series of compliance
measures. A monitor selected by the United States in its sole
discretion will be appointed for a term of three years, which the
United States may extend by up to 18 months if it deems appropriate.
RealPage will also adopt a written antitrust compliance policy and
train its employees on the policy. RealPage must allow the United
States to inspect its documents and to interview its employees to
ensure compliance with the Final Judgment, among other requirements.
Finally, RealPage must provide cooperation to the United States in
this civil proceeding (United States et al. v. RealPage et al.) with
respect to the United States' Section 1 claims against the non-settling
landlord defendants.
Under the terms of the Stipulation and Order, RealPage must abide
by and comply with the provisions of the proposed Final Judgment until
it is entered by the Court or until the time for all appeals of any
Court ruling declining entry of the proposed Final Judgment has
expired.
The United States and RealPage have stipulated that the proposed
Final Judgment may be entered by the Court after compliance with the
APPA. Entry of the proposed Final Judgment will terminate this action
with respect to the United States' claims against RealPage, except that
the Court will retain jurisdiction to construe, modify, or enforce the
provisions of the proposed Final Judgment and to punish violations
thereof by RealPage.
III. Standard of Judicial Review
The Clayton Act, as amended by the APPA, requires that proposed
consent judgments in antitrust cases brought by the United States be
subject to a 60-day comment period, after which the Court shall
determine whether entry of the proposed Final Judgment ``is in the
public interest.'' 15 U.S.C. 16(e)(1). In making that determination,
the Court, in accordance with the Tunney Act as amended in 2004, is
required to consider:
(A) the competitive impact of such judgment, including
termination of alleged violations, provisions for enforcement and
modification, duration of relief sought, anticipated effects of
alternative remedies actually considered, whether its terms are
ambiguous, and any other competitive considerations bearing upon the
adequacy of such judgment that the court deems necessary to a
determination of whether the consent judgment is in the public
interest; and
(B) the impact of entry of such judgment upon competition in the
relevant market or markets, upon the public generally and
individuals alleging specific injury from the violations set forth
in the complaint including consideration of the public benefit, if
any, to be derived from a determination of the issues at trial.
15 U.S.C. 16(e)(1)(A) & (B). In considering these statutory factors,
the Court's inquiry is necessarily a limited one, as the government is
entitled to ``broad discretion to settle with the defendant within the
reaches of the public interest.'' United States v. Microsoft Corp., 56
F.3d 1448, 1461 (D.C. Cir. 1995); United States v. US Airways Grp.,
Inc., 38 F. Supp. 3d 69, 75 (D.D.C. 2014) (explaining that the
``court's inquiry is limited'' in Tunney Act settlements); United
States v. InBev N.V./S.A., No. 08-1965 (JR), 2009 U.S. Dist. LEXIS
84787, at *3 (D.D.C. Aug. 11, 2009) (noting that a court's review of a
consent judgment is limited and only inquires ``into whether the
government's determination that the proposed remedies will cure the
antitrust violations alleged in the complaint was reasonable, and
whether the mechanism to enforce the final judgment are clear and
manageable''); United States v. Keyspan Corp., 763 F. Supp. 2d 633,
637-38 (S.D.N.Y. 2011); see SEC v. Citigroup Global Mkts. Inc., 673
F.3d 158, 168 (2d Cir. 2012) (``We are bound in such matters to give
deference to an executive agency's assessment of the public
interest.'').
As the U.S. Court of Appeals for the District of Columbia Circuit
has held, under the APPA, a court considers, among other things, the
relationship between the remedy secured and the specific allegations in
the government's complaint, whether the proposed Final Judgment is
sufficiently clear, whether its enforcement mechanisms are sufficient,
and whether it may positively harm third parties. See Microsoft, 56
F.3d at 1458-62; United States v. Apple, Inc., 889 F. Supp. 2d 623, 631
(S.D.N.Y. 2012) (citing Microsoft, 56 F.3d at 1458, 1461-62). With
respect to the adequacy of the relief secured by the proposed Final
Judgment, a court may ``not make de novo determination of facts and
issues.'' United States v. W. Elec. Co., 993 F.2d 1572, 1577 (D.C. Cir.
1993) (quotation marks omitted); see also Microsoft, 56 F.3d at 1460-
62; United States v. Alcoa, Inc., 152 F. Supp. 2d 37, 40 (D.D.C. 2001);
United States v. Enova Corp., 107 F. Supp. 2d 10, 16 (D.D.C. 2000);
InBev, 2009 U.S. Dist. LEXIS 84787, at *3. Instead, ``[t]he balancing
of competing social and political interests affected by a proposed
antitrust consent decree must be left, in the first instance, to the
discretion of the Attorney General.'' W. Elec. Co., 993 F.2d at 1577
(quotation marks omitted). ``The court should bear in mind the
flexibility of the public interest inquiry: the court's function is not
to determine whether the resulting array of rights and liabilities is
one that will best serve society, but only to confirm that the
resulting settlement is within the reaches of the public interest.''
Microsoft, 56 F.3d at 1460 (quotation marks omitted); see also United
States v. Deutsche Telekom AG, No. 19-2232 (TJK), 2020 WL 1873555, at
*7 (D.D.C. Apr. 14, 2020). More demanding requirements would ``have
enormous practical consequences for the government's ability to
negotiate future settlements,'' contrary to congressional intent.
Microsoft, 56 F.3d at 1456. ``The Tunney Act was not
[[Page 25376]]
intended to create a disincentive to the use of the consent decree.''
Id.\4\
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\4\ See also United States v. BNS Inc., 858 F.2d 456, 464 (9th
Cir. 1988) (holding that the court's ``ultimate authority under the
[APPA] is limited to approving or disapproving the consent
decree''); United States v. Gillette Co., 406 F. Supp. 713, 716 (D.
Mass. 1975) (noting that, in this way, the court is constrained to
``look at the overall picture not hypercritically, nor with a
microscope, but with an artist's reducing glass'').
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The United States' predictions about the efficacy of the remedy are
to be afforded deference by the Court. See, e.g., Microsoft, 56 F.3d at
1461 (recognizing courts should give ``due respect to the Justice
Department's . . . view of the nature of its case''); United States v.
Iron Mountain, Inc., 217 F. Supp. 3d 146, 152-53 (D.D.C. 2016) (``In
evaluating objections to settlement agreements under the Tunney Act, a
court must be mindful that [t]he government need not prove that the
settlements will perfectly remedy the alleged antitrust harms[;] it
need only provide a factual basis for concluding that the settlements
are reasonably adequate remedies for the alleged harms.'') (internal
citations omitted); United States v. Republic Servs., Inc., 723 F.
Supp. 2d 157, 160 (D.D.C. 2010) (noting ``the deferential review to
which the government's proposed remedy is accorded''); United States v.
Archer-Daniels-Midland Co., 272 F. Supp. 2d 1, 6 (D.D.C. 2003) (``A
district court must accord due respect to the government's prediction
as to the effect of proposed remedies, its perception of the market
structure, and its view of the nature of the case''). In determining
whether a proposed settlement is in the public interest, a district
court ``is not permitted to reject the proposed remedies merely because
the court believes other remedies are preferable.'' United States v.
Morgan Stanley, 881 F. Supp. 2d 563, 567 (S.D.N.Y. 2012) (quoting
United States v. Abitibi-Consol. Inc., 584 F. Supp. 2d 162, 165 (D.D.C.
2008)). The ultimate question is whether ``the remedies [obtained by
the Final Judgment are] so inconsonant with the allegations charged as
to fall outside of the `reaches of the public interest.' '' Microsoft,
56 F.3d at 1461 (quoting W. Elec. Co., 900 F.2d at 309).
Moreover, the Court's role under the APPA is limited to reviewing
the remedy in relationship to the violations that the United States has
alleged in its complaint, and the APPA does not authorize the Court to
``construct [its] own hypothetical case and then evaluate the decree
against that case.'' Microsoft, 56 F.3d at 1459; see also US Airways,
38 F. Supp. 3d at 75 (noting that the court must simply determine
whether there is a factual foundation for the government's decisions
such that its conclusions regarding the proposed settlements are
reasonable); Keyspan Corp., 763 F. Supp. 2d at 637-38 (``The Court's
function is not to determine whether the proposed [d]ecree results in
the balance of rights and liabilities that is the one that will best
serve society, but only to ensure that the resulting settlement is
`within the reaches of the public interest.' '' (quoting United States
v. Alex. Brown & Sons, Inc., 963 F. Supp. 235, 238 (S.D.N.Y. 1997));
InBev, 2009 U.S. Dist. LEXIS 84787, at *20 (``the `public interest' is
not to be measured by comparing the violations alleged in the complaint
against those the court believes could have, or even should have, been
alleged''). Because the ``court's authority to review the decree
depends entirely on the government's exercising its prosecutorial
discretion by bringing a case in the first place,'' it follows that
``the court is only authorized to review the decree itself,'' and not
to ``effectively redraft the complaint'' to inquire into other matters
that the United States did not pursue. Microsoft, 56 F.3d at 1459-60.
See also Heckler v. Chaney, 470 U.S. 821, 832 (1985) (quoting U.S.
Const. art. II, Sec. 3) (recognizing that the decision about which
claims to bring ``has long been regarded as the special province of the
Executive Branch'').
In its 2004 amendments to the APPA, Congress made clear its intent
to preserve the practical benefits of using consent judgments proposed
by the United States in antitrust enforcement, Public Law 108-237 Sec.
221, and added the unambiguous instruction that ``[n]othing in this
section shall be construed to require the court to conduct an
evidentiary hearing or to require the court to permit anyone to
intervene.'' 15 U.S.C. 16(e)(2); see also US Airways, 38 F. Supp. 3d at
76 (indicating that a court is not required to hold an evidentiary
hearing or to permit intervenors as part of its review under the Tunney
Act). This language explicitly wrote into the statute what Congress
intended when it first enacted the Tunney Act in 1974. As Senator
Tunney explained: ``[t]he court is nowhere compelled to go to trial or
to engage in extended proceedings which might have the effect of
vitiating the benefits of prompt and less costly settlement through the
consent decree process.'' 119 Cong. Rec. 24598 (1973) (statement of
Sen. Tunney). ``A court can make its public interest determination
based on the competitive impact statement and response to public
comments alone.'' US Airways, 38 F. Supp. 3d at 76 (citing Enova Corp.,
107 F. Supp. 2d at 17).
IV. Summary of Public Comments and the United States' Response
The United States received eight public comments from seven
commenters in response to the proposed Final Judgment. These comments
were submitted by the American Antitrust Institute (``AAI Comment'')
and by private individuals, whom the United States will refer to by
each individual's initials: AK (``AK Comment''), BA (``BA Comment''),
CC (``CC Comment''), DR (``DR Comment'' and ``DR Supplemental
Comment''), JP (``JP Comment''), and ST (``ST Comment'').\5\
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\5\ The JP Comment also includes comments about the proposed
Final Judgment between the United States and Greystar, Inc. The
United States addressed JP's comments about its proposed Final
Judgment with Greystar in the United States' Response to Public
Comments on the Greystar Final Judgment. See Doc. 169.
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A. The AAI Comment
The AAI submitted some questions and recommendations related to the
proposed Final Judgment. The United States responds to each in turn.\6\
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\6\ In the response below, the United States may refer to
specific sections and paragraphs of the proposed Final Judgment, and
all capitalized terms (e.g., ``Unaffiliated Property Data,''
``Runtime Operation'') are as defined in the proposed Final
Judgment.
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1. How do the individual terms of the agreement serve to prevent
RealPage from coordinating the exchange of data and setting common
pricing rules?
The proposed Final Judgement explicitly limits RealPage's ability
to coordinate the exchange of data among landlords. Paragraphs IV.A-B
require RealPage, among other restrictions, to (i) cease using current
or historical Unaffiliated Property Data in the Runtime Operation; (ii)
notify licensees that RealPage does not seek the use of Unaffiliated
Property Data; (iii) cease using current, forward-looking, or
historical Unaffiliated Property Data or Owner Inputted Data unless the
data is aged; (iv) not share, publish, disclose, or otherwise make
accessible in a Revenue Management Product (including in Runtime
Operation) to any licensee of a Revenue Management Product any
Unaffiliated Property Data or Owner Inputted Data from a different
Property Owner. Paragraph VI.A further requires Pricing Advisors not to
disclose, share with, or otherwise disseminate Unaffiliated Property
Data or Owner Inputted Data in the Revenue Management Product or for
purposes or recommending floor plan pricing, unit level pricing, or
occupancy levels.
[[Page 25377]]
Given these restrictions, RealPage will not retain ``significant
leeway'' to use competitors' nonpublic data to make pricing
recommendations.\7\
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\7\ AAI Comment at 2.
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AAI also comments on terms of the proposed Final Judgment that
serve to prevent RealPage from coordinating what AAI calls ``common
pricing rules.'' The Complaint alleges specific mechanisms by which
RealPage aligned pricing among landlords, including the use of
guardrails designed into the revenue management software and RealPage-
sponsored meetings with landlords. (E.g., Doc. 47 at ]] 102-16, 142-
52.) Paragraphs V.A-B of the proposed Final Judgment restrict
RealPage's ability to use these guardrails in this alleged
anticompetitive manner. Paragraph VI.B of the proposed Final Judgment
prohibits RealPage from discussing or facilitating discussions of
market analyses or trends based on nonpublic data or any pricing
strategies, whether based on nonpublic or public data. The Complaint
does not allege that adoption and use of the same revenue management
software by competing landlords, standing alone, is necessarily
anticompetitive; instead, it is RealPage's specific design of its
software, and landlords' agreements to use that software as designed,
that results in anticompetitive pricing alignment.\8\
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\8\ The AAI Comment's speculation as to the impact of the
proposed Final Judgment's required geographic limitations, see AAI
Comment at 6-7, misunderstands the connection between the specific
output of the AIRM AI Demand and Supply Models and the AIRM price
recommendation generated in runtime operation. The geographic
limitations at issue apply to model training and thus affect only
the output of the AIRM AI Demand and Supply Models, for example. By
contrast, the restrictions on runtime operation inherently and
implicitly incorporate a geographic dimension through their
reference to competing properties. See infra IV.A.5.
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2. What is the quantity and scope of the Owner Inputted Data that
RealPage is allowed to use in its Runtime Operations under the
agreement, and why is such use of competitor data consistent with the
goals and principles laid out in the CIS?
Owner Inputted Data refers to data that is directly inputted by
landlords into a revenue management product and includes both public
and nonpublic data. (Doc. 159-1 at ] II.U.) As alleged in the
Complaint, landlords directly exchanged competitively sensitive
information to update rents within another RealPage revenue management
product known as Lease Rent Options or LRO. (Doc. 47 at ]] 99-100.)
Because Owner Inputted Data may include both public and nonpublic data,
the proposed Final Judgment restricts how RealPage can use Owner
Inputted Data. First, RealPage is not allowed to use any Owner Inputted
Data in model training. The proposed Final Judgment does not provide
any exception to this restriction. (Doc. 159-1 at ] IV.A.3.) Second,
RealPage is not allowed to share, publish, disclose, or otherwise make
accessible in a revenue management product any Owner Inputted Data
inputted by another Property Owner or a Property Manager acting on the
Owner's behalf. In other words, RealPage may not use Owner Inputted
Data in the Runtime Operation for a property from a different Property
Owner for which it was inputted. (Doc. 159-1 at ] IV.B.) Third, Pricing
Advisors are not allowed to disclose, share, or otherwise disseminate
Owner Inputted Data nor is RealPage allowed to discuss or facilitate
discussions about market analysis or trends based on Owner Inputted
Data. (Doc. 159-1 at ] VI.A-B.) Finally, RealPage must notify all
Property Managers or Property Owners that license or use RealPage's
Revenue Management Products that RealPage may not seek Unaffiliated
Property Data for use in Runtime Operation, including Owner Inputted
Data. (Doc. 159-1 at ] IV.A.2.) These restrictions address the
anticompetitive conduct alleged in the Complaint because they eliminate
RealPage's use of potentially nonpublic data from different owners in
determining rental prices or pricing recommendations.\9\
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\9\ While outside of the scope of RealPage's proposed Final
Judgment, the United States' Final Judgments with Cortland
Management, LLC (Doc. 184) and Greystar Management Services, LLC
(Doc. 172), and its proposed Final Judgment with LivCor, LLC (Doc.
164-1) prohibit disclosing, soliciting, or using nonpublic data from
a third-party for setting rental prices or generating rental pricing
recommendations. This would include inputting nonpublic data from a
third-party into any revenue management product, in line with the
stated objection of stopping the exchange and use of competitor data
in setting prices. (See also Docs. 63, 155, and 168 (competitive
impact statements for the settlements with these landlords).)
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3. How will the individual terms of the agreement prevent RealPage from
continuing to facilitate anticompetitive coordination notwithstanding
its limits on the use of certain data, particularly with respect to
RealPage's continued ability to recommend above-market prices to its
licensees?
Please refer to answers IV.A.1 and IV.A.4.
4. Considering the DOJ's allegations that RealPage's price
recommendations raise market prices even when they are not accepted,
how will the proposed settlement's limits on RealPage's software
features serve to prevent it from raising market prices?
The proposed Final Judgment eliminates the means by which the
Complaint alleges that RealPage harms the competitive process and
renters. First, the Complaint alleges that the agreement among RealPage
and landlords to share nonpublic, competitively sensitive information
is anticompetitive because it harms the competitive process. (Doc. 47
at ]] 260-269.) A result of the unlawful information sharing is an
increase in rents, harming renters. (See, e.g., Doc. 47 at ] 127.)
Second, the Complaint alleged that the design of AIRM and YieldStar,
including certain product features such as the Hard Floor and Governor
Guardrail, harms the competitive process and likely results in an
alignment of pricing for competing properties in local markets.\10\
(See Doc. 47 at ]] 271-279.)
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\10\ As alleged in the Complaint, AIRM and YieldStar will not
recommend a floor plan price that falls below the smoothed market
minimum effective rent. The market minimum is a hard floor. AIRM and
YieldStar thus explicitly constrain floor plan price recommendations
based on the prices of competitors, using shared nonpublic
information. (Doc. 47 at ] 143.)
As alleged in the Complaint, AIRM and YieldStar favor
recommended price increases over price decreases. When the model
calculates that the current day's ``optimal'' price will result in
greater revenue than the previous day, a feature called the
``governor'' causes the model to recommend the current day's optimal
price. (Id. at ] 151.)
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The proposed Final Judgment addresses both avenues of competitive
harm. As explained above in II and IV.A.1, RealPage is restricted from
using competitors' nonpublic, competitively sensitive data to provide
pricing recommendations or prices to a landlord. And the restrictions
on product design features shift decision-making and product
customization from RealPage to the property management companies or
property owners, reducing the possibility of pricing alignment between
competitors in a given market and promoting independent decision-making
on pricing and other competitive elements. For example, Auto Accept and
the Governor Guardrail require a licensee or user to set the specific
parameters, and the Governor Guardrail must be symmetrical in upper and
lower bounds. (Doc. 159-1 at ]] IV.A.1-2.) The Sold-out Guardrail must
now only use the Subject Property's own information, regardless of
whether the
[[Page 25378]]
data is public or nonpublic. (Doc. 159-1 at ] IV.A.3.) RealPage cannot
implement an asymmetric hard floor and must allow users to go below a
pricing floor to the same extent they can go above a pricing ceiling.
(Doc. 159-1 at ] V.B.) Finally, Paragraph V.D. of the proposed Final
Judgment prohibits RealPage from implementing any product feature that
uses competitors' nonpublic data in a way that is inconsistent with the
terms set forth in the proposed Final Judgment. (Doc. 159-1 at ] IV.D.)
By promoting decentralized, independent decision-making, expanding
the range of user choices, and generally eliminating shared nonpublic
information in Runtime Operation to inform recommendations, the
proposed Final Judgment addresses the United States' concerns that AIRM
and YieldStar harm the competitive process and thereby harm renters
through higher rents or pricing behavior that is more likely to produce
higher rents.
5. Considering the sophistication of RealPage's models and its ability
to supplement training with granular, up-to-date, location-specific
public data, how does the agreement prevent RealPage from continuing to
develop and implement collusive pricing rules?
The Complaint alleges anticompetitive effects based on RealPage's
use of nonpublic data to set prices for competing properties. The
proposed Final Judgment addresses these concerns. (See Doc. 159-1 at ]]
IV.A.) The restrictions include: (i) restrictions on RealPage's use of
Unaffiliated Property Data in runtime operation; (ii) requiring
RealPage to age certain nonpublic data for model training; and (iii)
restrictions on RealPage's use of models that filter or can identify
geographic effects below a nationwide and, in some circumstances,
statewide scope.
The Complaint also alleges that certain product features tended to
align pricing. To remedy this concern, the proposed Final Judgment's
provisions shift decision-making and product customization from
RealPage to each property management company or property owner,
reducing the possibility of collusive pricing. For example, Auto Accept
and the Governor Guardrail require a licensee or user to set the
specific parameters. (Doc. 159-1 at ]] IV.A.1-2.) The Sold-out
Guardrail must now only use the Subject Property's own information,
regardless of whether the data is public or nonpublic. (Doc. 159-1 at ]
IV.A.3.) Finally, Paragraph V.D. prohibits RealPage from implementing
any product feature that is inconsistent with the terms set forth in
the proposed Final Judgment. (Doc. 159-1 at ] IV.D.)
These restrictions address the United States' concerns regarding
RealPage's use of nonpublic data and product design features that align
pricing among competing landlords.
6. The DOJ Should Resolve the Ambiguity or Otherwise Clarify the
Meaning of Paragraph IV.A.1, Including By Amending Paragraph IV.A.1 and
the Definitions of ``Subject Property,'' Unaffiliated Property,'' and
``Unaffiliated Property Data'' and Any Other Provisions Necessary To
Resolve Any Ambiguity or Confusion
The proposed Final Judgment provides definitions for these terms,
eliminating ambiguity. RealPage's software provides pricing
recommendations and prices for the floor plans and units within a
specific Subject Property. Per Paragraph II.JJ, ``Subject Property'' is
a property for which a Revenue Management Product provides price
recommendations or prices. In other words, a Subject Property refers
to, as described by the commenter, ``one property at any given time-the
property to which RealPage's software is currently providing price
recommendations in a given Runtime Operation.'' \11\ ``Unaffiliated
Property,'' as defined in Paragraph II.OO, refers to a property or
properties that do not have the same Property Owner as the Subject
Property. Finally, Paragraph II.PP defines ``Unaffiliated Property
Data'' as the nonpublic data from an Unaffiliated Property.
---------------------------------------------------------------------------
\11\ AAI Comment at 4.
---------------------------------------------------------------------------
Paragraph IV.A.1 prohibits the use of Unaffiliated Property Data in
Runtime Operation. In other words, RealPage may not ``use the real-time
[nonpublic] data of all licensees as an input to make price
recommendations to any one licensee.'' \12\ Rather, it is limited in
Runtime Operation to using nonpublic data from a given Property Owner
to make rental price recommendations for that Property Owner's specific
property. (See Doc. 159-1 at ]] II.F and IV.A.)
---------------------------------------------------------------------------
\12\ AAI Comment at 3.
---------------------------------------------------------------------------
The United States believes the terms are properly defined and it is
not necessary to amend the proposed Final Judgment.
7. The DOJ Should Appoint a Monitor With the Necessary Expertise To
Ensure That RealPage Complies With Both the Letter and the Spirit of
the Agreement as Finalized
Under the proposed Final Judgment, the United States has sole
discretion to select the monitor to be appointed by the Court. (Doc.
159-1 at ] VII.A.) The United States agrees with the commenter's
suggestion for the appointment of a monitor with the necessary
expertise to properly monitor compliance with the terms of the Final
Judgment.
8. The DOJ Should Continue To Monitor Rental Prices in the Affected
Markets Listed in the Complaint To Ensure That the Limitations on
RealPage's Conduct Effectively Prevent It From Raising Rental Prices
Above the Competitive Level. If Such Monitoring Suggests That the use
of RealPage's Products Continues to Result in Supracompetitive Prices
in the Relevant Markets, the DOJ Should Reopen the Matter and/or Modify
Its Decree Accordingly
Paragraphs IX.A-B provide the United States continued compliance
inspection rights related to any matters contained in the Final
Judgment. Relatedly, Paragraph XIII.A permits the United States to re-
open the proceedings to seek additional relief should the Final
Judgment fail to address the violations alleged in the Complaint.
B. The AK Comment
AK describes herself as a renter in South Dakota. AK does not
believe the proposed Final Judgment goes far enough to address price-
fixing concerns. The commenter provides four examples of where the
proposed Final Judgment is allegedly too weak.
First, AK describes perceived loopholes and ``exceptions to
exceptions'' that would allow RealPage to ``approximate much of the
earlier behavior.'' \13\ As an example, AK explains that the consent
decree ``doesn't say that RealPage can't offer similar synthetic curve
to different clients,'' essentially providing competitors a ``slightly
tweak[ed]'' list of prices.\14\ The proposed Final Judgment is designed
to restrict the use of nonpublic data and some product features that,
as alleged in the Complaint, harmed the consumers and the competitive
process. While there are exceptions to the use of nonpublic data, these
exceptions were carefully considered given how the data would be used.
For example, while there is an
[[Page 25379]]
exception to using Unaffiliated Property Data in Runtime Operation,
this is limited to properties that do not have ``comparable Surrogate
Data available from the same reasonably identifiable Property Owner.''
(Doc. 159-1 at ] IV.C.) RealPage, however, may not use the same data in
the Runtime Operation for a competing property in the same CBSA. In
addition to limiting the nonpublic data that can be used, the proposed
Final Judgment requires RealPage to further customize its revenue
management software to the specific needs and goals of each property
management company or property owner. Finally, the commenter
misunderstands synthetic curves. Synthetic curves are not created from
a list of prices. A Synthetic Curve is ``a demand or supply curve
created by [RealPage or RealPage's] agents without the use of
Transactional Data or Nonpublic Data of any kind.'' (Doc. 159-1 at ]
II.LL.) Transactional Data includes both public and nonpublic current
and historical data. (Doc. 159-1 at ] II.NN.) These synthetic curves,
if used, would be one of multiple inputs to determine a price
recommendation. Therefore, the commenter's conclusion that RealPage
would be able to ``slightly tweak'' a ``list of prices'' is incorrect.
---------------------------------------------------------------------------
\13\ AK Comment at 1.
\14\ AK Comment at 1.
---------------------------------------------------------------------------
Second, AK is concerned with the proposed Final Judgment allowing
RealPage to continue to offer pricing advisory services. The commenter
believes that RealPage's pricing advisors will continue to advise
clients to increase rents based on a different client's nonpublic data.
The proposed Final Judgment prohibits this conduct. Pricing advisors
must not ``disclose, share with, or otherwise disseminate Unaffiliated
Property Data or Owner Inputted Data'' through the revenue management
products or for purposes of recommending rental pricing or occupancy
levels. (Doc. 159-1 at ] VI.A.) The proposed Final Judgment provides
for various mechanisms, such as a monitor, certifications, and the
United States' authority to inspect documents and records, to ensure
RealPage's compliance with this provision. (See id. ]] VIII.C.3, VII.K,
IX.A-B.)
Third, AK states that the settlement does not require RealPage to
``disgorge any of the profit it made through illegal collusive price-
fixing.'' \15\ The United States did not allege a claim of price-fixing
in its Complaint.
---------------------------------------------------------------------------
\15\ AK Comment at 1.
---------------------------------------------------------------------------
Fourth, AK is concerned that RealPage is allowed to ``keep all the
old data that it gathered unlawfully and build models upon it.'' \16\
The proposed Final Judgment imposes restrictions on what data RealPage
may use to train its models. RealPage is not allowed to use ``current,
forward-looking, or historical'' data from unaffiliated properties
except that it may use historical or backward-looking data from
unaffiliated properties that is at least 12 months old and not from
active leases. (Doc. 159-1 at ] IV.A.3.) The proposed Final Judgment
further restricts RealPage's ability to use its models to identify
geographic effects narrower than nationwide and build models that would
calculate market rent or market rank. (Doc. 159-1 at ] IV.A.4-5.) These
restrictions are significant. RealPage models cannot be trained using
nonpublic data that represent the current competitive conditions in the
market, nor can RealPage use such data to determine rental prices at a
relevant geographic level in which competition for conventional
multifamily rentals occurs.\17\
---------------------------------------------------------------------------
\16\ AK Comment at 2.
\17\ As described in the Complaint, geographic markets for
conventional multifamily housing are inherently local because
``renters are typically tied to a particular location for work,
family, or other needs.'' (Doc. 47 at ] 200.)
---------------------------------------------------------------------------
C. The BA Comment
BA describes himself as a pricing professional and a RealPage user.
BA believes that the proposed Final Judgment will harm competition and
consumers and that the Court should deny entry of the proposed Final
Judgment. BA argues that the Complaint did not demonstrate
anticompetitive effects, failed to address procompetitive arguments for
sharing data, and that the proposed remedy is not connected to the
harm.
First, BA argues that Plaintiffs ``[assume] harm rather than
demonstrating it'' and comments on the lack of expert testimony on
``market dynamics.'' \18\ These comments are outside the scope of
Tunney Act review, which focuses on whether the proposed Final Judgment
adequately resolves the United States' antitrust claims against
RealPage.
---------------------------------------------------------------------------
\18\ BA Comment at 2-3.
---------------------------------------------------------------------------
Second, BA alleges that Plaintiffs failed to address the
``procompetitive arguments for sharing data.'' \19\ Again, such
comments are outside the scope of Tunney Act review.
---------------------------------------------------------------------------
\19\ BA Comment at 3.
---------------------------------------------------------------------------
Finally, the commenter argues that ``even if one accepts entirely
DOJ's argument that the harm outweighs the procompetitive benefits,''
the proposed settlement is not connected to the harm alleged.\20\ The
commenter further states that the Complaint ``alleges price fixing
agreements'' but the remedy is ``not about agreements or price
fixing.'' \21\ The commenter misstates the allegations in the
Complaint.
---------------------------------------------------------------------------
\20\ BA Comment at 7.
\21\ BA Comment at 7.
---------------------------------------------------------------------------
First, the Complaint alleges that Defendants, including RealPage,
unlawfully shared information for use in competitors' pricing. The
proposed Final Judgment restricts RealPage's use of nonpublic data in
RealPage's Revenue Management Products. (Doc. 159-1 at ] IV.A-C.)
Further, RealPage will not be able to ``conduct, commission, solicit,
or otherwise knowingly accept'' nonpublic data through market surveys
for use in its Revenue Management Products or for recommending rental
pricing or occupancy levels. (Doc. 159-1 at ] IV.D.) Finally, the
proposed Final Judgment restricts RealPage's ability to use, share,
publish, or disclose competitors' data through Revenue Management
Products, Pricing Advisors, or in RealPage Revenue Management Meetings.
(Doc. 159-1 at ]] IV.E and VI.A-B.)
Second, the Complaint alleges that Defendants, by agreeing to use
the software as designed and intended, agreed to align users' pricing
processes, strategies, and pricing responses. (Doc. 47 at ]] 270-279.)
The proposed Final Judgment addresses these concerns. Paragraphs V.A-D
impose restrictions on RealPage's product features, such as Auto Accept
and the Governor Guardrail, that the Complaint alleges aligned pricing
between competitors. (See, e.g., Doc. 47 at ] 142-152.)
Finally, the Complaint alleges that RealPage has unlawfully
monopolized, or attempted to monopolize, the commercial revenue
management software market. (Doc. 47 at ]] 280-289.) The Complaint also
alleges RealPage engaged in unlawful exclusionary conduct based on
RealPage's use of competitively sensitive data from competing landlords
to market and sell AIRM and YieldStar. As discussed earlier, the
proposed Final Judgment limits RealPage's ability to use competitively
sensitive data in competing landlords' pricing. (Doc. 159-1 at ] IV.A-
C.) Therefore, the proposed Final Judgment addresses Plaintiffs' final
claim.
The terms of the proposed Final Judgment directly remedy the
conduct alleged in Plaintiffs' Complaint. Therefore, the United States
believes that the proposed Final Judgment addresses the claims alleged
in the Complaint.
[[Page 25380]]
D. The CC Comment
CC describes herself as a resident of a property in South Dakota.
CC explains that in November 2025, the property management company
notified tenants of a mandatory digital rent payment mechanism for
tenants. Digital payment mechanisms are not relevant to the Complaint's
claims and are thus outside the scope of the Tunney Act review.
E. The DR Comments
DR describes herself as a resident at a multifamily building in
Minnesota. DR raises concerns regarding her building's use of
RealPage's OneSite, RealPage Utility Management, and YieldStar
products. In particular, the commenter is concerned that by using these
RealPage products, rent and utility bills might be inflating overall
housing costs.\22\ Additionally, DR requests that (1) full disclosure
is provided to tenants regarding the use of algorithmic pricing and how
pricing is calculated; (2) the United States ensures compliance with
Minneapolis's ordinance banning algorithmic rent-setting; (3) the
United States investigates whether the commenter's building practices
contribute to patterns of algorithmic rent-setting; and (4) the United
States considers additional oversight into properties not included in
the proposed Final Judgment.\23\
---------------------------------------------------------------------------
\22\ DR Comment at 1 and 5.
\23\ DR Comment at 6; DR Supplemental Comment at 3.
---------------------------------------------------------------------------
DR's concerns regarding the use of RealPage Utility Management and
RealPage's Onesite products, compliance with the Minneapolis ordinance
banning algorithmic rent-setting, and investigating whether the
commenter's building practices contribute to algorithmic price setting
are not relevant to the Complaint's claims and are thus outside the
scope of the Tunney Act review.
DR further suggests full disclosure to tenants on how price is
calculated. This suggestion falls outside the scope of the Court's
review under the Tunney Act because the proposed Final Judgment applies
only to RealPage, and not to any landlord that licenses and uses
RealPage's revenue management products in leasing its properties to
tenants.
Finally, DR suggests that the terms of the proposed Final Judgment
be expanded to other properties. This suggestion also falls outside the
scope of the Tunney Act review because the proposed Final Judgment
applies only to RealPage, and not to any landlord that licenses and
uses RealPage's revenue management products in leasing its properties
to tenants.
F. The JP Comment
JP describes himself as a resident of a Greystar property in
Atlanta, Georgia. JP is concerned that the proposed Final Judgment with
RealPage does not impose financial penalties on RealPage, does not
include an admission of wrongdoing by RealPage, allows RealPage to
continue using certain data for model training, and does not
``adequately address the ongoing harms to vulnerable populations.''
\24\
---------------------------------------------------------------------------
\24\ JP Comment at 3.
---------------------------------------------------------------------------
The United States did not seek financial penalties as a remedy for
the violations alleged in its Complaint.
JP also comments that the RealPage settlement does not include an
admission of wrongdoing. The Tunney Act, however, does not require a
settlement to include an admission of wrongdoing as a prerequisite to
judicial approval. See Morgan Stanley, 881 F. Supp. 2d at 568. On the
contrary, the statute specifically excepts consent judgments like this
one from being prima facie evidence or having a collateral estoppel
effect in another action or proceeding. See 15 U.S.C. 16(a)(``A final
judgment or decree heretofore or hereafter rendered in any civil or
criminal proceeding brought by or on behalf of the United States under
the antitrust laws to the effect that a defendant has violated said
laws shall be prima facie evidence against such defendant in any action
or proceeding brought by any other party against such defendant under
said laws as to all matters respecting which said judgment or decree
would be an estoppel as between the parties thereto: Provided, That
this section shall not apply to consent judgments or decrees entered
before any testimony has been taken.'') (emphasis added). Congress has
designed the remedial provisions of the antitrust laws to encourage
consent judgments, which allow the government to obtain relief without
the ``time, expense and inevitable risk of litigation.'' United States
v. Armour and Co., 402 U.S. 673, 681 (1971). See also United States v.
Nat'l Ass'n of Broadcasters, 553 F. Supp. 621, 623 (DDC 1982)
(``Congress apparently enacted this proviso in order to encourage
defendants to settle promptly government-initiated antitrust claims and
thereby to save the government the time and expense of further
litigation.''). To insist on more would impose substantial resource
costs on government antitrust enforcement, risk the possibility of
litigation resulting in no relief, and establish a precedent that could
impede enforcement of the antitrust laws in the future.
JP is also concerned that the proposed Final Judgment will allow
RealPage to continue using certain data for model training. Paragraph
IV.A.3 of the proposed Final Judgment prohibits RealPage from using
current, forward-looking, or historical nonpublic data in training its
revenue management software models, unless the data are at least 12
months old and not from active leases.\25\ The data aging requirements
effectively eliminate active leases--i.e., a unit with a rental
agreement that is in effect--from the process of training the supply
and demand models. These restrictions address the competitive concerns
alleged in the Complaint.
---------------------------------------------------------------------------
\25\ Doc. 159-1.
---------------------------------------------------------------------------
Finally, JP is concerned that the settlement does not address
``ongoing harm to vulnerable populations'' and subsidized tenants.\26\
JP's concerns are not relevant to the Complaint`s claims and are thus
outside the scope of the Tunney Act review.
---------------------------------------------------------------------------
\26\ JP Comment at 4.
---------------------------------------------------------------------------
G. The ST Comment
ST believes that the restrictions in the RealPage proposed Final
Judgment prohibiting the use of nonpublic data in runtime operation,
aging data, and removing features that limited price decreases or
aligned prices are ``vital to restoring competitive conditions in
rental markets.'' \27\ ST raises concerns related to low-income
residents who live in properties assisted by the U.S. Department of
Housing and Urban Development. According to ST, these individuals face
heightened risks when algorithmic tools ``indirectly shape owner's
expectations and submissions to HUD.'' ST suggests additional
conditions related to HUD-assisted properties related to HUD pricing
certifications and compliance.\28\ These concerns are outside the scope
of the Tunney Act review because they are not relevant to the
Complaint`s claims, which do not involve HUD-assisted properties.
---------------------------------------------------------------------------
\27\ SK Comment at 1.
\28\ SK Comment at 1-2.
---------------------------------------------------------------------------
To the extent that commenters wish to raise the possibility of
additional unlawful conduct not addressed by the Complaint brought in
this matter, members of the public are encouraged to submit information
about any antitrust violation, including potentially unlawful exchanges
of information between competitors, to the Department of Justice
Antitrust Division's Citizen
[[Page 25381]]
Complaint Center (<a href="https://www.justice.gov/atr/report-violations">https://www.justice.gov/atr/report-violations</a>).
V. Conclusion
After careful consideration of the public comments, the United
States continues to believe that the proposed Final Judgment provides
an effective and appropriate remedy for the antitrust violations
alleged in the Complaint and is therefore in the public interest. The
United States will move this Court to enter the proposed Final Judgment
after the comments and this response are published in a manner approved
by the Court, as required by 15 U.S.C. 16(d).
Dated: April 30, 2026
Respectfully submitted,
By:
-----------------------------------------------------------------------
Henry C. Su,
David A. Geiger,
Danielle Hauck,
Kris A. Perez Hicks,
Attorneys, United States Department of Justice, Antitrust Division,
450 Fifth Street NW, Suite 7100, Washington, DC 20530, Telephone:
(202) 307-6200, Email: <a href="/cdn-cgi/l/email-protection#aac2cfc4d8d384d9dfeadfd9cec5c084cdc5dc"><span class="__cf_email__" data-cfemail="b8d0ddd6cac196cbcdf8cdcbdcd7d296dfd7ce">[email protected]</span></a>
[FR Doc. 2026-09147 Filed 5-7-26; 8:45 am]
BILLING CODE 4410-11-P
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