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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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184. The Defendant Landlords accepted and retained the conferred benefit.

185. Under the circumstances, it would be inequitable for the Defendant Landlords to

retain the benefit without paying for it.

186. As a result of their unlawful conduct described herein, the Defendant Landlords

have been and will continue to be unjustly enriched by the receipt of monies from rent at

unlawfully inflated prices and unlawful profits from the same.

187. The common-law principle of unjust enrichment prohibits the Defendant

Landlords from retaining the benefits conferred on them by the overpayments from renters

within Kentucky.

DEMAND FOR RELIEF

WHEREFORE, Plaintiff, the Commonwealth of Kentucky, respectfully requests that the

Court enter judgment in its favor and against Defendants, as follows:

a. Entering an Order finding that the Defendants have violated the Sherman Act, the

Kentucky Consumer Protection Act, as well as the common law of Kentucky as set forth herein,

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and have been unjustly enriched by such, and that judgment be entered against Defendants in favor

of Plaintiff;

b. Granting Plaintiff all recoverable measures of damages—including but not limited

to treble damages—allowable under the claims identified herein;

c. Awarding Plaintiff penalties of up to $2,000.00 per willful violation of the KCPA

pursuant to KRS § 367.990(2);

d. Awarding civil penalties of $10,000 for each violation of the Kentucky Consumer

Protection Act pursuant to KRS § 367.990(2), where Defendants’ conduct was directed at a person

aged sixty (60) years of age or older;

e. Awarding civil penalties of five thousand dollars ($5,000) or two hundred dollars

($200) per day for each and every violation of KRS § 367.175.