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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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suppressed price competition in the markets for conventional multifamily housing. The relevant
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geographic markets to assess those agreements are those property locations close enough for

their apartments to be considered reasonable substitutes. In delineating a geographic market for

conventional multifamily housing, the focus is inherently local. Renters are typically tied to a

particular location for work, family, or other needs.

149. In Kentucky there are numerous geographic submarkets, including, but not

limited to, the Greater Cincinnati, Louisville, and Lexington-Fayette markets.

VI. CAUSES OF ACTION

COUNT I
Price Fixing in Violation of
Section 1 of the Sherman Act (15 U.S.C. § 1)

150. The Commonwealth reasserts, realleges, and incorporates by reference each of

Paragraphs 1-149, above, as though fully set forth herein.

151. During the Conspiracy Period (further investigation and discovery may reveal an

earlier date), and continuing through the present, Defendants and their co-conspirators entered

into and engaged in a contract, combination, or conspiracy to unreasonably restrain trade in

violation of Section 1 of the Sherman Act (15 U.S.C. § 1).

152. The contract, combination, or conspiracy consisted of an agreement among

Defendants and their co-conspirators to fix, raise, stabilize, or maintain at artificially high levels

the price of multifamily rental housing in Kentucky and involved the exchange of competitively

sensitive information between and among Defendants, causing anticompetitive effects without

sufficient procompetitive justifications.

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 153. Defendant Landlords have agreed with RealPage to delegate rent price-setting

responsibility to RealPage for multifamily housing units in the Commonwealth, rather than