Notice2026-22832
United States of America, et al. v. RealPage, Inc., et al.; Response of the United States 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
November 9, 2026
Issuing agencies
Justice DepartmentAntitrust Division
Full Text
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<title>Federal Register, Volume 91 Issue 215 (Monday, November 9, 2026)</title>
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[Federal Register Volume 91, Number 215 (Monday, November 9, 2026)]
[Notices]
[Pages 70898-70905]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-22832]
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DEPARTMENT OF JUSTICE
Antitrust Division
United States of America, et al. v. RealPage, Inc., et al.;
Response of the United States 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 Comments on the Proposed Final Judgment in United
States of America et al. v. RealPage et al., Civil Action No. 24-cv-
00710, regarding Defendant Willow Bridge Property Company, LLC, has
been filed in the United States District Court for the Middle District
of North Carolina, together with the comments. Copies of the public
comments and the United States' Response are also 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 Plaintiff, vs. WILLOW BRIDGE PROPERTY
COMPANY, LLC, Defendant.
No. 1:24-cv-00710
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 two public comments
received regarding the proposed Final Judgment as to Defendant Willow
Bridge Property Company, LLC (Doc. 200-1).\1\
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\1\ The United States has redacted personally identifiable
information from the comments prior to filing them with this
response. 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.
After this response and the public comments have been published in
the Federal Register pursuant to 15 U.S.C Sec. 16(d), the United
States will move the Court to enter the proposed Final Judgment.
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 civil Complaint (the ``Complaint'') to add Willow Bridge Property
Company, LLC (``Willow Bridge'') and five other landlords as Defendants
(Doc. 47) alleging that Willow Bridge's agreements with RealPage and
other landlords to share information and align pricing violate Section
1 of the Sherman Act, 15 U.S.C. 1. The Complaint seeks to enjoin
Defendants from sharing and exploiting competitively sensitive data.
On July 6, 2026, the United States filed a proposed Final Judgment
(Doc. 200-1) as to Willow Bridge, which is designed to remedy the loss
of competition alleged in the Complaint due to Willow Bridge's conduct,
and a Stipulation and Proposed Order (Doc. 200), in which Willow Bridge
consented to entry of the proposed Final Judgment after compliance with
the requirements of the Tunney Act.\2\ Also on the same date, the
United States filed a Competitive Impact Statement describing the
proposed Final Judgment as to Willow Bridge. (Doc. 202)
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\2\ The Stipulation and Proposed Order, and the proposed Final
Judgment, pertain only to Willow Bridge's conduct. They do not
propose to resolve the anticompetitive conduct alleged in the
Complaint against any other Defendant. Nor do they resolve the
claims of any other Plaintiff besides the United States.
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The United States arranged for the publication of the Complaint,
proposed Final Judgment, and Competitive Impact Statement in the
Federal Register on July 16, 2026, see 15 U.S.C. 16(b)-(c); 91 FR
43,774 (July 16, 2026), 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 and the
Greensboro News and Record from July 14 to July 21, 2026. The 60-day
period for public comment has now ended. The United States received two
comments in response, which are described below and attached as
Exhibits 1 & 2 hereto.
II. The Complaint and The Proposed Final Judgment
The Complaint alleges that, by unlawfully sharing its confidential
and competitively sensitive information with RealPage for use in its
and competing landlords' pricing, Willow Bridge violated Section 1 of
the Sherman Act, 15 U.S.C. 1. Under their licensing agreements with
RealPage, Willow Bridge and competing landlords have provided RealPage
with daily, competitively sensitive, nonpublic information for use in
RealPage's revenue management software relating to the landlords'
leasing businesses, including details like how many leases have been
renewed, for what terms, and at what price. The transactional data that
Willow Bridge and other landlords have agreed to provide to RealPage
includes current, forward-looking, granular, and highly competitively
sensitive information. RealPage has
[[Page 70899]]
used Willow Bridge's competitively sensitive, nonpublic information to
influence rental prices and other recommendations across rental
properties managed by competing landlords. Willow Bridge's rental
prices and related recommendations were likewise influenced by its
competitors' competitively sensitive, nonpublic information obtained
from RealPage. In each relevant market, RealPage and participating
landlords, including Willow Bridge, have sufficient market power,
including market and data penetration, to harm renters and the
competitive process through this unlawful sharing of confidential and
competitively sensitive information. Moreover, Willow Bridge and other
landlords can achieve any procompetitive objective of revenue
management software without sharing this kind of information.
The Complaint also alleges that Willow Bridge and other landlords,
by adopting and using RealPage's revenue management software, agreed
with RealPage to align their pricing and thereby violate Section 1 of
the Sherman Act, 15 U.S.C. 1. RealPage has entered into agreements with
Willow Bridge and its competing landlords relating to how to price
rental units, including through the licensing of its revenue management
software--AI Revenue Management (``AIRM''), YieldStar, and Lease Rent
Options (``LRO'')--to landlords, and the provision by landlords of
their competitively sensitive, nonpublic transactional data to RealPage
for training and running its revenue management software. Adoption and
use of RealPage's revenue management software by Willow Bridge and
other landlords have the likely effect of causing competing landlords
to employ the same or very similar strategies, processes, and decisions
relating to their pricing of rental units. Willow Bridge and other
landlord users understand this likely effect, which here dampens the
competitive process that benefits renters.
The proposed Final Judgment imposes several requirements and
restrictions on Willow Bridge that address the United States'
anticompetitive concerns regarding Willow Bridge's conduct alleged in
the Complaint. Specifically:
i. Willow Bridge must not license or use any revenue management
product that uses third-party nonpublic data to recommend or set
prices;
ii. Willow Bridge must not license or use any revenue management
product that pools information from Willow Bridge properties that have
different owners;
iii. Willow Bridge must not disclose, solicit, or use competitively
sensitive information from competitors that can be used to set rental
prices or generate pricing;
iv. Willow Bridge must cooperate in this civil antitrust proceeding
(United States et al. v. RealPage et al.);
v. Willow Bridge must adopt a written antitrust compliance policy
and designate a chief antitrust compliance officer who will train
Willow Bridge employees on the policy;
vi. Willow Bridge must allow the United States to inspect its
documents and to interview its employees to ensure compliance with the
Final Judgment;
vii. If Willow Bridge uses a revenue management product, Willow
Bridge will be subject to a monitor unless Willow Bridge obtains a
certification that meets certain requirements, including an affirmation
that the product complies with all required limitations regarding use
of competitors' competitively sensitive data; and
viii. If, in the future, the Court finds that Willow Bridge has
violated the terms of the proposed Final Judgment, Willow Bridge will
be subject to a court-appointed monitor.
Under the terms of the Stipulation and Order, Willow Bridge 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 Willow Bridge 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 Willow Bridge,
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 Willow Bridge.
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.
Hewlett Packard Enterprise Co., No. 25-CV-00951-PCP, 2026 WL 2349970,
at *16 (N.D. Cal. Aug. 12, 2026); United States v. U.S. 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 Markets 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
[[Page 70900]]
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 intended to create
a disincentive to the use of the consent decree.'' Id.\3\
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\3\ 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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``Because enforcement by consent decree is an alternative to
enforcement by trial or abandonment of the litigation altogether and
often reflects the United States's assessment of litigation risk, a
proposed settlement does not need to replicate the full relief that
[the] United States sought in its complaint.'' Hewlett Packard Enter.,
2026 WL 2349970, at *17. 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 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 U.S. 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); United States v. Keyspan Corp., 763 F. Supp. 2d 633 637-38
(S.D.N.Y. 2011) (``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 U.S. 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. 24,598 (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.'' U.S. 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 two public comments in response to the
proposed Final Judgment. The comments were submitted by private
individuals, whom the United States will refer to by each individual's
initials: MC (``MC Comment'') and JD (``JD Comment'').
A. The MC Comment
MC's comment requests that the United States consider whether the
proposed Final Judgment adequately addresses the role of pricing
algorithms in renewal pricing, including situations where renewal
prices offered are materially higher than prices quoted to prospective
tenants for the same apartment unit, and ``whether monitoring under the
decree should
[[Page 70901]]
examine the differences between renewal and new-tenant prices.'' \4\
The terms of the proposed Final Judgment with Willow Bridge do not make
a distinction between renewal pricing and new-tenant pricing.
Therefore, the limitations imposed on the use, disclosure, pooling,
combination, or training of Nonpublic Data apply equally to
recommendations regarding renewal pricing and new-tenant pricing
generated by revenue management software.\5\
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\4\ MC Comment at 2 (requests nos. 1, 2, and 5).
\5\ Willow Bridge Proposed Final Judgment, ]] IV.A-C and V.A.1
(Doc. 200-1).
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Furthermore, the Complaint did not allege anticompetitive conduct
related to differences between renewal pricing and new-tenant pricing.
(See, e.g., Doc. 47, ] 62 (``Every morning, the landlord's property
manager chooses whether to accept the floor plan price recommendation,
keep the previous day's rent, or override the recommendation. These
options are the same for new leases and renewal leases.'') & ] 107
(``Specifically, he urged the group to `push up new and renewal pricing
where demand [is] solid' and warned against over-relying on
concessions. They were instead to `trust the science' of
YieldStar.'').) MC's requests therefore are not relevant to the United
States' claims and not germane to Tunney Act review.
The fact that Willow Bridge may choose to price its apartment units
differently to existing tenants and prospective tenants does not, in of
itself, present a competitive concern, absent evidence that such a
pricing strategy uses Nonpublic Data shared by Willow Bridge's
competitors or aligns with the pricing strategy used by Willow Bridge's
competitors in a local rental market. The terms of the proposed Final
Judgment ensure that any differential pricing of renewals and new
leases by Willow Bridge is not a result of the types of anticompetitive
conduct alleged in the Complaint.
MC further requests that the United States consider whether the
proposed Final Judgment should require Willow Bridge to provide
notification to tenants on a property's use of ``automated revenue
management systems.'' \6\ Such a requirement would go beyond addressing
the United States' claims regarding the sharing of competitively
sensitive data among landlords and the use of revenue management
software to align their pricing. The use of an ``automated revenue
management system'' or software with a rental property, standing alone,
does not raise competitive concerns. What matters is whether such a
system or software is being trained on or otherwise uses Nonpublic Data
shared by Willow Bridge's competitors and whether such a system or
software, during operation, ``automates'' pricing recommendations and/
or decision-making for Willow Bridge and its competitors who are also
using the system or software. The proposed Final Judgment effectively
addresses such scenarios associated with Willow Bridge's use of an
``automated revenue management system.'' More is therefore not
required.
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\6\ MC Comment at 2 (request no. 3).
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Finally, MC requests that the United States consider whether the
proposed Final Judgment should require Willow Bridge to provide
``meaningful human review'' of renewal prices.\7\ Similar to MC's other
requests, this request questions whether a landlord like Willow Bridge
should be allowed to use revenue management software, and specifically
software that may automatically generate pricing recommendations for
renewals and new leases. As explained above, the United States'
Complaint does not allege that Willow Bridge's use of a revenue
management system or software, standing alone, is anticompetitive. What
matters is whether such a system or software is being trained on or
otherwise uses Nonpublic Data shared by Willow Bridge's competitors and
whether such a system or software, during operation, ``automates''
pricing recommendations and/or decision-making for Willow Bridge and
its competitors who are also using the system or software. The proposed
Final Judgment effectively addresses such scenarios associated with
Willow Bridge's use of revenue management software, and a requirement
of ``meaningful human review'' is neither relevant nor necessary to
address the competitive concerns raised by the Complaint.
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\7\ Id. at 2 (request no. 4).
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B. The JD Comment
JD first requests that the United States investigate whether their
specific rental property uses a RealPage or other third-party revenue
management product and whether their specific property's rental prices
were calculated with the use of competitively sensitive information.\8\
JD further requests that the United States explain ``whether
potentially affected renters will have any process to learn whether
their property or its data was within the investigation or remedial
program.'' \9\ A renter can ``evaluate whether the decree protects that
renter.'' \10\ In the United States' judgment, the type of process
requested by JD is not necessary. The proposed Final Judgment applies
to all conventional multifamily rental properties, located within the
United States or its territories, that are serviced by Willow Bridge
(defined as ``Willow Bridge Properties'').\11\ It therefore would apply
to JD's specific rental property if it is a Willow Bridge Property. As
for JD's request for any investigative information specific to their
rental property, the United States is prohibited by statute from
disclosing these materials.\12\ The United States notes, however, that
the Complaint identifies multiple geographic markets in Appendices A &
B, which the public may consult to understand the scope and extent of
the competitive harms being addressed by the proposed Final Judgment.
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\8\ JD Comment at 1-2.
\9\ Id. at 2.
\10\ Id.
\11\ Willow Bridge Proposed Final Judgment ] II.T (Doc. 200-1);
Willow Bridge Competitive Impact Statement at 12 (Doc. 202).
\12\ See 15 U.S.C. 1313(c)(3).
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JD also requests that the proposed Final Judgment require
independent technical verification of third-party revenue management
products.\13\ Although the proposed Final Judgment does not require
independent technical verification, it requires third-party revenue
management providers to provide certifications that the software
complies with the terms of the proposed Final Judgment.\14\
Furthermore, the United States has the right to obtain and inspect the
code and pseudocode of Willow Bridge's proprietary revenue management
software.\15\
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\13\ JD Comment at 3.
\14\ Willow Bridge Proposed Final Judgment ] V.E (Doc. 200-1).
\15\ Willow Bridge Proposed Final Judgment ] X.D (Doc. 200-1).
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JD recommends that the United States require Willow Bridge's
internal annual audit to include a ``statistically and operationally
meaningful sample.'' \16\ The proposed Final Judgment requires an
internal audit of employees ``engaged in or overseeing Willow Bridge's
revenue management of multifamily rental properties in the United
States and its territories,'' and at least 12 ``randomly selected,
local, regional, or supervisory employees who manage property
operations.'' \17\ This is sufficient to capture the scope and
diversity of Willow Bridge's revenue management operations, and there
is no need to expand or otherwise modify the
[[Page 70902]]
audit requirement. Importantly, the proposed Final Judgment provides
the United States broad rights to ensure compliance with the Final
Judgment. These include access to ``electronic copies of all books,
ledgers, accounts, records, data, and documents'' and to Willow
Bridge's employees for interviews relating to any matters contained in
the Final Judgment.\18\
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\16\ JD Comment at 3.
\17\ Willow Bridge Proposed Final Judgment ] VII.A (Doc. 200-1).
\18\ Willow Bridge Proposed Final Judgment ] X.A (Doc. 200-1).
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JD also requests that Willow Bridge be required to provide a public
annual compliance report. The compliance report should include,
according to the commenter, ``the number of properties and units under
each category of revenue-management product'' and information regarding
compliance and corrective actions.\19\ An annual compliance report of
this nature is not necessary. Moreover, such a report would be at odds
with the proposed Final Judgment's prohibitions against public
disclosure of information and documents obtained pursuant to any of its
provisions.\20\ Disclosure would also create a risk that competitively
sensitive information relating to Willow Bridge will be made public
which could lead to coordination among competing landlords.
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\19\ JD Comment at 3-4.
\20\ Willow Bridge Proposed Final Judgment ] XI (Doc. 200-1).
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JD recommends that the proposed Final Judgment make ``unmistakably
clear'' that structured datasets containing competitors' nonpublic
information may not be accessed, used, combined, retained without
controls, and require ``documented segregation, access restriction,
deletion or defensible inaction, and testing to prevent legacy data
from entering recommendations or model training.'' \21\ The proposed
Final Judgment already includes such a provision. Paragraph VI.C. of
states that Willow Bridge must not ``use or access, as part of setting
rental prices or generating rental pricing recommendations for any
Willow Bridge property, any External Nonpublic Data . . . including
such data derived from any RealPage Revenue Management Product.'' \22\
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\21\ JD Comment at 4.
\22\ Willow Bridge Proposed Final Judgment ] VI.C (Doc. 200-1).
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JD also points to the definition of ``Willow Bridge Property'' and
notes that it excludes ``student, affordable, age-restricted or senior,
and military housing.'' \23\ The commenter requests that if
``operational differences justify particular exceptions, those
exceptions should be narrowly tailored.'' The United States' Complaint
alleges a product market for conventional multifamily conventional
housing that does not include student, age-restricted, and military
housing (Doc. 47, ] 183). This portion of the commenter's request is
therefore outside the scope of the Complaint and is not subject to
Tunney Act consideration.
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\23\ JD Comment at 4.
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JD proposes that early termination of the Final Judgment by the
United States should be based on a ``reasoned public determination,''
and involve a process that includes ``public notice.'' \24\ The
proposed Final Judgment already provides that a request for early
termination would involve a public notice to the Court (and to Willow
Bridge) that continuation of the Final Judgment is no longer necessary
or in the public interest.\25\
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\24\ Id.
\25\ Willow Bridge Proposed Final Judgment ] XIV (Doc. 200-1).
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JD questions the proposed Final Judgment's cap of 15 employees and
60 total hours for cooperation with the litigation.\26\ This comment
fails to recognize that cooperation is not the only way that the United
States can develop evidence. In any investigation or litigation, the
United States always has procedural tools to compel the production of
documents and testimony.\27\ The cap in the proposed Final Judgment,
which is the product of a negotiated settlement, does not in any way
hamstring the United States' ability to obtain discovery in its
litigation against any other defendant in this action.
---------------------------------------------------------------------------
\26\ JD Comment at 4.
\27\ See 15 U.S.C. 1312, Fed. R. Civ. P. 30, 34 & 45.
---------------------------------------------------------------------------
Finally, JD asks why the proposed Final Judgment does not include
any monetary relief.\28\ The proposed Final Judgment does not provide
for restitution because it is not one of the remedies sought by the
United States in its Complaint.
---------------------------------------------------------------------------
\28\ JD Comment at 4.
---------------------------------------------------------------------------
* * * * *
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 Complaint Center (<a href="https://www.justice.gov/atr/webform/pcsf-citizen-complaint">https://www.justice.gov/atr/webform/pcsf-citizen-complaint</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 against Willow Bridge 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: November 5, 2026
Respectfully submitted,
By: /s/ Henry C. Su
-----------------------------------------------------------------------
Henry C. Su,
David A. Geiger,
Danielle G. Hauck
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#442c212a363d6a3731043137202b2e6a232b32"><span class="__cf_email__" data-cfemail="88e0ede6faf1a6fbfdc8fdfbece7e2a6efe7fe">[email protected]</span></a>.
Certificate of Service
I hereby certify that on November 5, 2026, I electronically
filed the foregoing with the Clerk of the Court using the CM/ECF
system, which will send notification of such filing to all counsel
of record.
By: /s/ Henry C. Su
/s/ Henry C. Su-------------------------------------------------------
Henry C. Su
Certificate of Word Count
I hereby certify that, based on the word count tool in Microsoft
Word, the foregoing document contains 4,814 words, exclusive of the
caption, signature lines, certificate of service, and any cover page
or index, and it therefore complies with the limitation on length
set forth in Local Civil Rule 7.3(d).
Dated: November 5, 2026
By: /s/ Henry C. Su
/s/ Henry C. Su-------------------------------------------------------
Henry C. Su
EXHIBIT 1--MC Comment (Redacted)
From: [REDACTED]
To: ATR-Public-Comments-Tunney-Act-MB
Subject: [EXTERNAL] Public Comment--Willow Bridge Proposed Final
Judgment--1:24-cv-00710
Date: Monday, September 14, 2026 11:54:14 p.m.
Attachments: image0.png, image1.png, image2.png, image3.png
Good evening,
I am submitting this comment regarding the proposed Final
Judgment involving Willow Bridge Property Company LLC in United
States et al. v. RealPage, Inc. et al., Civil Action No. 1:24-cv-
00710.
I am a current resident of [REDACTED] in Dallas, Texas, a Willow
Bridge-managed community.
My current lease expires [REDACTED]. On [REDACTED], I received a
renewal offer for my apartment that included the following rates:
[[Page 70903]]
10 months--$1,734/month
11 months--$1,628/month
13 months--$1,622/month
14 months--$1,629/month
15 months--$1,631/month
I recently checked my property's public website and discovered
that my exact apartment, is already being marketed to a prospective
new resident, with availability beginning [REDACTED].
The publicly advertised rates for Apartment [REDACTED] include:
10 months--$1,536/month
11 months--$1,526/month
13 months--$1,517/month
14 months--$1,524/month
15 months--$1,527/month
16 months--$1,517/month
Thus, Willow Bridge is currently offering prospective new
renters materially lower rents for the exact same apartment than it
offered me to remain in the apartment. Additionally, a concession of
4 weeks free is being offered to all one bedroom floor plans that
has been explicitly denied to me.
For example, my 10-month renewal rate was $1,734, while the
publicly advertised 10-month rate for my apartment is $1,536--a
difference of $198 per month. My 14-month renewal rate was $1,629
compared with an advertised $1,524, and my 15-month renewal rate was
$1,631 compared with an advertised $1,527.
I have screenshots of the public listing and a copy of my
written renewal offer documenting these amounts.
I do not know whether my renewal rates or the currently
advertised rates were generated, recommended, or influenced by
RealPage, AIRM, YieldStar, or another revenue-management system. I
am not asserting that this pricing discrepancy alone proves an
antitrust violation.
However, because the government's allegations against Willow
Bridge concern algorithmic rental pricing and the use of
competitively sensitive information in determining rents, I believe
this current pricing experience is relevant to whether the proposed
Final Judgment adequately protects renters.
In particular, I respectfully ask the Department to consider
whether the proposed decree adequately addresses:
1. pricing algorithms used for lease renewals, not merely rents
quoted to prospective tenants;
2. situations in which incumbent tenants are offered materially
higher prices than the contemporaneous public price for their own
apartment;
3. whether tenants should be told when an automated revenue-
management system materially influenced their renewal rate;
4. whether Willow Bridge should be required to provide
meaningful human review of renewal prices; and
5. whether monitoring under the decree should examine
differences between renewal pricing and new-tenant pricing at the
same property.
I am providing this information so that the Department and Court
have the benefit of a current Willow Bridge resident's experience
while evaluating whether the proposed relief is sufficient to
protect competition and renters.
Thank you for considering my comment.
[REDACTED]
Dallas, Texas
[Screenshots Redacted]
Exhibit 2--JD Comment (Redacted)
From: [REDACTED]
To: ATR-Public-Comments-Tunney-Act-MB
Subject: [EXTERNAL] Public Comment--Proposed Willow Bridge Final
Judgment--U.S. v. RealPage, No. 1:24-cv-00710
Date: Friday, September 11, 2026 1:27:48 p.m.
Dear Ms. Hauck:
I am a [REDACTED] resident of [REDACTED] in Chula Vista,
California, a multifamily community publicly listed/managed by
Willow Bridge Property Company.
I have lived at [REDACTED] for approximately one year, and
Willow Bridge has managed the community throughout my residency. My
own tenancy has raised unresolved financial and pricing-related
concerns involving Willow Bridge's administration of rent and other
housing charges. I do not claim in this comment that those concerns
resulted from RealPage, competitor data, or an antitrust violation.
They are why the adequacy and verifiability of this decree are
concrete questions for me rather than abstract policy concerns. I am
willing to provide relevant records through a nonpublic channel if
the Department determines that a property-level inquiry is
warranted.
I respectfully ask the Antitrust Division to strengthen the
proposed Final Judgment with Willow Bridge Property Company LLC, or
explain on the public record why the existing provisions are
sufficient, before asking the Court to find the settlement in the
public interest.
My relationship to a Willow Bridge-managed community explains
why the decree matters to me; it is not offered as evidence that the
alleged antitrust conduct occurred at [REDACTED]. This comment
relies only on the public record: the amended complaint, proposed
Final Judgment, Competitive Impact Statement, Federal Register
notice, Willow Bridge's public property listing, and the
Department's public case materials. It does not ask the Department
to decide any private tenancy dispute. The amended complaint
contains allegations, not adjudicated facts, and Willow Bridge's
consent to the proposed judgment is not an admission of liability.
Those limits make independent verification of future compliance more
important, not less.
Property-Specific Public-Interest Question: [REDACTED]
My concern is not abstract. Willow Bridge's current public
website presents [REDACTED] as one of its communities. The
California Department of Real Estate currently lists the [REDACTED]
address as a branch of Willow Bridge Management Inc., a corporation
using the DBAs ``Willow Bridge'' and ``Willow Bridge Property
Company.'' A 2022 City of Chula Vista staff report described
[REDACTED] as a [REDACTED] property owned by John Hancock Life
Insurance Company (U.S.A.) since 2015. I cite the City report as a
dated public representation, not as proof of current title.
DOJ's amended complaint alleges that Willow Bridge used
RealPage's AIRM and YieldStar products. It also alleges more broadly
that RealPage obtained confidential transactional data through
products including OneSite, Performance Analytics with Benchmarking,
and Business Intelligence--including data from units that did not
necessarily use AIRM or YieldStar--and made such data available for
pricing recommendations. The complaint does not identify [REDACTED]
or Chula Vista, and I do not claim that [REDACTED] used any of these
products or that its data entered the challenged system. The absence
of property-level public information is precisely why I ask DOJ to
examine the question.
I respectfully request that the Department, within its existing
investigative, preservation, and compliance authority:
1. determine whether [REDACTED] used AIRM, YieldStar, LRO,
OneSite, Performance Analytics with Benchmarking, Business
Intelligence, or another RealPage or third-party revenue-management
or data product during the period relevant to the complaint and
proposed judgment;
2. determine whether [REDACTED] nonpublic rents, concessions,
applications, lease terms, renewals, occupancy, availability, or
other competitively sensitive information were transmitted, pooled,
benchmarked, used for model training, or made available to generate
recommendations for [REDACTED] or competing properties;
3. determine whether pricing or leasing recommendations used at
[REDACTED] were influenced by competitors' nonpublic information;
4. preserve the relevant property-level contracts, product
records, data-flow records, configurations, recommendations,
overrides, communications, and audit trails, and ensure that the
decree's legacy-data and compliance provisions reach [REDACTED] and
similarly situated properties managed for third-party owners; and
5. to the extent consistent with law-enforcement and
confidentiality constraints, explain in DOJ's response to public
comments whether potentially affected renters will have any process
to learn whether their property or its data was within the
investigation or remedial program.
These requests do not assume the answers. They ask DOJ to test a
concrete property against the precise data flows, products, owner-
manager relationships, and renter harms alleged in its own
complaint.
They also expose a practical transparency problem: a renter
cannot evaluate whether the decree protects that renter if property-
level coverage is known only to Willow Bridge, its vendors, and the
government.
Voucher-Assisted Residents and Public Funds
[REDACTED] makes the property-level pricing question more
consequential. In the federal [REDACTED] program, the public housing
agency may not approve the initial rent until it determines that the
rent to owner
[[Page 70904]]
is reasonable, must redetermine reasonableness before an increase,
and must compare the requested rent with comparable unassisted
units. The payment standard and gross rent also affect the housing-
assistance-payment calculation. See 24 CFR 982.505 and 982.507.
Accordingly, if competitor-informed or algorithmically
influenced pricing affected a requested initial rent, renewal
increase, comparable-unit submission, concession, or other pricing
input for a voucher-assisted unit, the effects could reach the
resident's housing cost, the agency's rent-reasonableness process,
and the expenditure of public subsidy funds. I do not assert that
this occurred in my tenancy. I ask DOJ to determine whether it
occurred at [REDACTED] or other Willow Bridge-managed properties
and, if the evidence indicates an effect on assisted units or agency
rent determinations, to coordinate as appropriate with HUD and the
administering public housing agencies.
The final judgment should also require Willow Bridge to identify
whether covered products or data practices were used in connection
with voucher-assisted units at otherwise conventional properties.
Its exclusion of ``affordable housing'' must not be interpreted to
remove an entire conventional property--or individual units--from
the decree merely because some residents use tenant-based rental
assistance.
I have separately submitted housing-accountability reports to
the HUD Office of Inspector General and VA Office of Inspector
General and initiated a housing intake with the California Civil
Rights Department. These are distinct processes. I do not represent
that any of those agencies has opened an investigation, accepted a
formal complaint, or made findings. I identify them only because
overlapping voucher, rent, property-management, and communications
records may warrant preservation or appropriate interagency referral
if DOJ identifies a nexus to the conduct alleged in this case.
The proposed judgment contains meaningful protections. It
broadly restricts the use and disclosure of competitors' nonpublic,
property-specific information; limits revenue-management products
that pool data across different owners; prohibits agreements with
other property managers or owners to use a product; restricts price
floors, automatic acceptance, and financial incentives tied to
accepting recommendations; bars participation in RealPage meetings;
preserves Department inspection rights; and provides contempt and
cost-shifting remedies. These are material safeguards.
The public-interest question, however, is whether those
safeguards can be verified and enforced across Willow Bridge's
national operating footprint. The Competitive Impact Statement
states that Willow Bridge manages more than 240,000 units. Against
that scale, several provisions appear too dependent on self-
reporting, vendor assurances, small samples, and nonpublic
oversight.
1. Require Independent Technical Verification and an Initial Monitoring
Period
The proposed judgment permits Willow Bridge to use a third-party
revenue-management product if the provider certifies that the
product meets the decree's requirements. It also appears to permit
use of a RealPage product without a separate certification if a
final judgment is entered against RealPage. A monitoring trustee is
not automatic: monitoring is principally tied to use of an
uncertified product or a judicial finding of a violation.
Vendor certification is useful evidence, but it is not
independent verification. The alleged conduct involved data flows,
model training, product settings, information exchanges, and
operational practices that can change after a certification is
issued. Reliance on a separate judgment against RealPage also does
not establish that Willow Bridge's configuration and use of a
product are compliant in practice.
I ask the Department to require:
--independent technical validation before initial use and after
material product, model, data-source, or configuration changes;
--testing of actual data inputs, model-training data, access
controls, recommendation settings, overrides, and outputs--not only
review of a vendor's written representations; and
--an independent monitoring trustee for at least the first two
years, with risk-based authority to examine products and practices
whether or not a violation has already been proved.
If the Department believes these protections are unnecessary,
its response should explain how vendor certification and a
contingent monitor provide equivalent assurance.
2. Scale the Audit Program to Willow Bridge's Footprint and Risk
The proposed judgment requires an annual audit of revenue-
management personnel and at least 12 randomly selected local,
regional, or supervisory property-operations employees. A minimum
sample of 12 employees is difficult to reconcile with a company
managing more than 240,000 units. Random selection alone can also
miss markets, properties, transition periods, or teams presenting
the greatest risk.
The final judgment should require a statistically and
operationally meaningful sample tied to the number of properties,
units, markets, products, and owners involved. The sample should
include risk-based selections, not merely random ones, and should
test management transitions, complaints, unusual override patterns,
product changes, and markets where multiple competing properties use
the same software. The audit should examine owners' instructions and
approvals when those instructions affect product use or pricing
practices.
3. Add Public, Aggregated Compliance Reporting
The proposed judgment gives the Department access to significant
nonpublic information, but it does not appear to require a public
annual compliance report. Monitoring reports are generally protected
from disclosure, and the public may never learn whether a monitor
was appointed, what products were used, whether violations were
detected, or whether corrective action occurred.
Confidential business information should remain protected. But
confidentiality does not require complete public opacity. The final
judgment should require an annual public report stating, in
aggregated and noncommercial terms:
--the number of properties and units using each category of revenue-
management product;
--the number and type of audits, technical tests, complaints, and
substantiated violations;
--the general nature and completion status of corrective actions;
--whether a monitoring trustee is serving and the scope of completed
review; and
--whether the Department has granted, rejected, or conditioned any
request affecting compliance.
Public reporting would allow affected renters and the Court to
assess whether the decree is functioning without disclosing rents,
algorithms, personal data, or competitively sensitive information.
4. Clarify Legacy-Data Controls and the Housing-Category Exclusions
The proposed judgment requires Willow Bridge to identify certain
structured datasets containing competitors' nonpublic information,
but states that the identification provisions do not apply to data
maintained in OneSite, Yardi Voyager, or other property-management
software. The final judgment should make unmistakably clear that
this storage-location language is not permission to access, use,
combine, retain without controls, or repurpose prohibited
information. It should require documented segregation, access
restriction, deletion or defensible inactivation, and testing
sufficient to prevent legacy data from entering recommendations or
model training.
The definition of ``Willow Bridge Property'' also excludes
student, affordable, age-restricted or senior, and military housing.
The public record should explain why residents and owners in those
sectors do not require the decree's core protections against
competitor data exchange and cross-owner pooling. The judgment
should also clarify that an otherwise conventional multifamily
property is not excluded merely because individual households use
tenant-based rental assistance. If operational differences justify
particular exceptions, those exceptions should be narrowly tailored;
the core information-sharing prohibitions should apply wherever the
competitive risk exists.
5. Condition Any Early Termination on a Public Compliance Record
The proposed judgment lasts five years but permits termination
after three years upon notice by the United States. Early
termination should require a reasoned public determination based on
completed independent testing, a record of corrective action, and
the absence of unresolved material violations. The Department should
provide public notice before early termination and give the Court
and the public a meaningful opportunity to assess the compliance
record.
[[Page 70905]]
6. Explain the Limits of the Remedy and Cooperation Provisions
The proposed judgment requires cooperation but caps voluntary
interviews under that provision at 15 employees and 60 total hours.
Formal discovery and civil investigative demands remain available.
Even so, given the alleged duration, nationwide scope, and technical
nature of the conduct, the Department should explain why those
ceilings are appropriate for voluntary cooperation, or replace them
with a reasonable-necessity standard.
The Competitive Impact Statement also recognizes that private
parties may pursue damages and that the proposed judgment will have
no prima facie effect in private litigation. The settlement contains
no restitution or monetary relief for renters. I recognize that a
Tunney Act review is not an individual claims process and that the
Court's role is not to rewrite the government's case. Still, the
Department should explain why forward-looking relief without
monetary redress is adequate in light of the complaint's allegations
and what public compliance information will allow potentially
affected renters to understand whether the challenged practices have
actually stopped.
Requested Disposition
I respectfully ask the Department to modify the proposed Final
Judgment to include the safeguards above before entry. At minimum,
the Department's response to public comments should address each
concern with enough specificity for the Court to evaluate whether
the decree's verification, transparency, duration, coverage, and
cooperation provisions are adequate for a company of Willow Bridge's
scale.
The decree should not depend on the public simply trusting the
participants and vendors whose future conduct it is designed to
constrain. Durable relief requires independent testing,
proportionate auditing, limited but meaningful transparency, and a
public basis for any early termination.
Respectfully submitted,
[REDACTED]
Sources Used:
1. U.S. Department of Justice, Antitrust Division, case page, *U.S.
and Plaintiff States v. RealPage, Inc.*, updated Sept. 4, 2026:
<a href="https://www.justice.gov/atr/case/us-and-plaintiff-states-v-realpage-inc">https://www.justice.gov/atr/case/us-and-plaintiff-states-v-realpage-inc</a>
2. Proposed Final Judgment as to Willow Bridge Property Company LLC,
filed July 6, 2026:
3. Competitive Impact Statement as to Willow Bridge Property Company
LLC, filed July 6, 2026: <a href="https://www.justice.gov/atr/media/1451166/dl">https://www.justice.gov/atr/media/1451166/dl</a>
4. Amended Complaint, filed Jan. 7, 2025: <a href="https://www.justice.gov/atr/media/1383471/dl">https://www.justice.gov/atr/media/1383471/dl</a>
5. Federal Register public-inspection notice, scheduled for
publication July 16, 2026: <a href="https://public-inspection.federalregister.gov/2026-14345.pdf">https://public-inspection.federalregister.gov/2026-14345.pdf</a>
6. U.S. Department of Justice, ``Justice Department Reaches Proposed
Settlement with Willow Bridge, One of America's Largest Landlords,''
July 7, 2026: <a href="https://www.justice.gov/opa/pr/justice-department-reaches-proposed-settlement-willow-bridge-one-americas-largest-landlords">https://www.justice.gov/opa/pr/justice-department-reaches-proposed-settlement-willow-bridge-one-americas-largest-landlords</a>
7. Willow Bridge Property Company, [REDACTED]
8. California Department of Real Estate, Willow Bridge Management
Inc., corporation license 01319176 and branch listing: <a href="https://www2.dre.ca.gov/publicasp/pplinfo.asp?License_id=01319176">https://www2.dre.ca.gov/publicasp/pplinfo.asp?License_id=01319176</a>
9. City of Chula Vista, 2022 staff report describing [REDACTED]
10. Electronic Code of Federal Regulations, 24 CFR 982.505, housing-
assistance-payment calculation: <a href="https://www.ecfr.gov/current/title-24/subtitle-B/chapter-IX/part-982/subpart-K/section-982.505">https://www.ecfr.gov/current/title-24/subtitle-B/chapter-IX/part-982/subpart-K/section-982.505</a>
11. Electronic Code of Federal Regulations, 24 CFR 982.507,
reasonable rent: <a href="https://www.ecfr.gov/current/title-24/subtitle-B/chapter-IX/part-982/subpart-K/section-982.507--">https://www.ecfr.gov/current/title-24/subtitle-B/chapter-IX/part-982/subpart-K/section-982.507--</a>
[REDACTED]
``It is impossible to think of anything at all in the world, or
even beyond it, that could be considered good without limitation
except a good will.''
--Immanuel Kant (Groundwork of the Metaphysics of Morals)
[FR Doc. 2026-22832 Filed 11-6-26; 8:45 am]
BILLING CODE 4410-11-P
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