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Ky. Off. of the Att'y Gen., Complaint, Commonwealth v. RealPage, Inc. (filed July 2, 2025)

Citation
Ky. Off. of the Att'y Gen., Complaint, Commonwealth v. RealPage, Inc. (filed July 2, 2025)
Jurisdiction
Kentucky (state)
Source
Official source

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properties surrogates that are distant student assets rather than nearby conventional assets.

RealPage in fact offers a different version of both AIRM and OneSite, its property management

software, for the “student market.”

141. Affordable housing units are available only to individuals or households whose

income falls below certain thresholds. Multiple federal affordable housing regulations, for

example, require participants in affordable housing programs to have incomes lower than a set

percentage, such as 30%, of the median family income in the local area. Affordable housing units

are also relatively scarce, with families seeking such housing often waiting years on a waitlist.

These legal and practical restrictions prevent affordable housing from being a reasonable

substitute to conventional multifamily housing for the typical renter.

142. Senior housing is typically restricted to individuals aged 55 and older. RealPage

separates senior housing into four categories: independent living, assisted living, memory care,

and nursing care. Independent living offers senior-focused amenities—such as transportation,

meals, and social gatherings among community members—that materially increase housing costs

and are less desirable to younger households. The other three categories of senior housing
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provide professional or special care to assist renters with basic tasks like eating, bathing, and

dressing, and they are not reasonable substitutes for conventional multifamily rentals.

143. Military housing is also not a reasonable substitute for conventional multifamily

rentals. It is typically geographically proximate to military installations, with roughly 95% of

military housing found on-base. Although civilians may in some cases be able to live in military