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

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

172. KRS § 367.170(1) states that “[u]nfair, false, misleading, or deceptive acts or

practices in the conduct of any trade or commerce are hereby declared unlawful.”

173. KRS § 367.170(2) states that “unfair shall be construed to mean unconscionable.”

174. Each time that RealPage provided a pricing recommendation within Kentucky, it

committed a separate unfair, false, misleading and/or deceptive act in violation of KRS §

367.170 because such a pricing recommendation was the result of collusion amongst competitors

and was willfully promulgated with the intent of depriving a renter of the benefits of

competition, including bargaining power.

175. Each time that a Defendant Landlord published, whether in print, online, or

otherwise, a rental price based on a RealPage pricing recommendation, that Defendant Landlord

committed a separate unfair and unconscionable act in violation of KRS § 367.170 because such

a rental price was the result of collusion amongst competitors and was willfully promulgated

with the intent of depriving a renter of the benefits of competition, including bargaining power.

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 176. Each time that a Defendant Landlord published, whether in print, online, or

otherwise, a rental price based on a RealPage pricing recommendation, that Defendant Landlord

committed a separate misleading and deceptive act in violation of KRS § 367.170 by willfully

omitting the fact that the rental price was set through collusion amongst competitors.

177. Pursuant to KRS § 367.190, the Commonwealth is entitled to injunctive relief