Question 1

Why did I get the notice?

Accepted Answer

The Notice
[https://angeion-public.s3.amazonaws.com/www.realpagerentalsettlement.com/docs/Long+Form+Notice.pdf]
explains the proposed Settlements in a class action lawsuit called In Re:
RealPage, Inc., Rental Software Antitrust Litigation (No. II),
3:23-MD-30711 (the “Action”), and the legal rights and options that you might
have as a potential member of the Settlement Class.

This case is pending in the United States District Court for the Middle District
of Tennessee, Nashville Division, the Honorable Waverly D. Crenshaw, Jr.,
presiding. The Notice is not an opinion of the Court regarding the claims in
this Action, and the Court must still decide whether to finally approve the
Settlements.

You have received the Notice because you may be a member of the Settlement
Class.  To find out if you are a member of the Settlement Class, see FAQ 5
[/faqs?id=5], below.

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1 The actions currently centralized in MDL No. 3071 include Case Nos.
3:22-cv-01082; 3:23-cv-00332; 3:23-cv-00357; 3:23-cv-00378; 3:23-cv-00413;
3:23-cv-00552; 3:23-cv-00742; and 3:23-cv-00979.

Question 2

What is this lawsuit about?

Accepted Answer

Plaintiffs in this Action are individuals who rented multifamily residential
housing in the United States or Puerto Rico. Multifamily housing refers to
residential property with more than one residential rental unit and is also
known as a multi-dwelling unit (e.g., apartment buildings). Plaintiffs allege
that Defendants participated in an unlawful conspiracy to fix and inflate rental
prices for multifamily residential housing in the United States and exchanged
competitively sensitive information about rental pricing and leasing, all in
violation of federal and state antitrust laws.2 Plaintiffs further allege that,
as a result of Defendants’ unlawful actions, Plaintiffs and the Settlement Class
were overcharged for their rents and had fewer places available to them for
rent. A copy of the Second Amended Consolidated Class Action Complaint
[https://angeion-public.s3.amazonaws.com/www.realpagerentalsettlement.com/docs/Second_Amended_Consolidated_Class_Action_Complaint.pdf],
setting out the details of the conspiracy and the claims asserted is available
on the Important Documents [/important-documents] page of this website.

Settling Defendants deny Plaintiffs’ allegations and any purported wrongdoing in
connection with the facts and claims that have been or could have been alleged
in the Action. Settling Defendants also assert that they have valid defenses to
Plaintiffs’ claims.

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2 Defendants are Essex Property Trust, Inc.; Independence Realty Trust, Inc.;
Morgan Properties Management Co., LLC; RealPage, Inc.; Thoma Bravo L.P.; Thoma
Bravo Fund XIII, L.P.; Thoma Bravo Fund XIV, L.P.; UDR, Inc.; and ZRS
Management, LLC and Settling Defendants.

Question 3

Why is this lawsuit a class action?

Accepted Answer

In a class action, people or businesses called plaintiffs acting as class
representatives sue not only for themselves but also on behalf of other people
or businesses with similar legal claims. Together, all people or businesses with
similar claims and interests form what is called a class, and the people or
businesses included are called class members (if the class is certified by a
court). One court resolves the issues for all class members. In this case, ten
Plaintiffs have been appointed to act as representatives of the Settlement Class
(“Settlement Class Representatives”) by the Court.

Question 4

Why is there a Settlement?

Accepted Answer

Plaintiffs and Settling Defendants have agreed to settle the case to avoid the
delays, costs, and the risk of trial, and any appeals that could follow a trial.
The Settlements allow Settlement Class Members to potentially receive
compensation, subject to Court approval, rather than risk ultimately receiving
nothing. Plaintiffs and Settlement Class Counsel (see FAQ 15 [/faqs?id=15],
below) believe the Settlements are in the best interests of all members of the
Settlement Class.

Question 5

How do I know if I am part of the Settlement Class?

Accepted Answer

Pursuant to the Court’s Preliminary Approval Order, the Settlement Class is
defined as follows:

All persons and entities in the United States and its territories who paid rent
on at least one multifamily residential real estate lease directly to any owner,
manager and/or owner-operator (including to any division, subsidiary,
predecessor, agent or affiliate of any owner, manager and/or owner-operator) on
a property subject to a license for RealPage’s Revenue Management Solutions,
Lease Rent Options (“LRO”), YieldStar (“YS”), and/or AI Revenue Management
(“AIRM”) (“RealPage’s RMS”) at any time during the period of October 18, 2018
through November 21, 2025 (the “Settlement Class Period”).

Specifically excluded from this Class is any Settlement Class Member who submits
a valid and timely request for exclusion that is accepted by the Court;
Defendants; any entity licensing RealPage’s RMS, the officers or directors of
any entity licensing RealPage’s RMS and any entity in which any entity licensing
RealPage’s RMS has a controlling interest; any affiliate, legal representative,
heir or assign of any entity licensing RealPage’s RMS; federal, state, or local
governments; states and their subdivisions, agencies, and instrumentalities; any
judicial officer presiding over this Action and the members of his/her immediate
family and judicial staff; and any juror assigned to this Action.

If you are not sure whether you are part of the Settlement Class, use the
Property List [/property-lookup] to see if your residential lease was in a
building that might be covered by the Settlements (“Property List”). Even if
your building is not on the Property List, you may still be a member of the
Settlement Class and may submit a claim for consideration; however, you are
eligible for a payment from the Settlement Fund only if you rented a unit on the
Property List.

For more information, you can contact the Settlement Administrator by phone,
email, or mail:

* Toll-Free: 1-888-995-4213
 * Email: info@RealPageRentalSettlement.com [info@RealPageRentalSettlement.com]
 * Mail: RealPage Rental Software Litigation, Settlement Administrator, P.O. Box
   59, East Brunswick, NJ 08816-9998

PLEASE NOTE: Receipt of the Notice or the fact that you rented from a property
on the Property List does not mean that you are a Settlement Class Member or
that you are entitled to receive proceeds from the Settlements.  If you are a
Settlement Class Member and wish to be eligible to participate in the
distribution of proceeds from the Settlements, you are required to submit a
Claim Form
[https://angeion-public.s3.amazonaws.com/www.realpagerentalsettlement.com/docs/Claim_Form.pdf]
and any required supporting documentation, which must be submitted online
[/submit-claim] or received by 11:59 p.m. EST on January 29, 2027.

FAQs

Basic Information

The Settlement Benefits

Excluding Yourself from the Settlements

Objecting to the Settlements

The Lawyers Representing You

The Court's Fairness Hearing

If You Do Nothing

Getting More Information

Important Notice Regarding Third-Party Claim Filing Services

Basic Information

1. Why did I get the notice?

2. What is this lawsuit about?

3. Why is this lawsuit a class action?

4. Why is there a Settlement?

5. How do I know if I am part of the Settlement Class?

The Settlement Benefits

6. What do these Settlements provide?

7. How do I ask for money from these Settlements?

8. How much money will I get?

Excluding Yourself from the Settlements

9. How do I exclude myself from the Settlement Class?

10. If I do not exclude myself, can I sue Settling Defendants and the other Releasees for the same thing later?

11. If I exclude myself from the Settlement Class, can I get money from these Settlements?

12. If I exclude myself from the Settlements, can I still object?

Objecting to the Settlements

13. How do I tell the Court if I do not like the Settlements?

14. What is the difference between objecting and excluding?

The Lawyers Representing You

15. Do I have a lawyer in this lawsuit?

16. How will the lawyers for Plaintiffs and the Settlement Class be paid?

The Court's Fairness Hearing

17. When and where will the Court decide whether to approve these Settlements?

18. Do I have to come to the Fairness Hearing?

19. What if I want to speak at the Fairness Hearing?

If You Do Nothing

20. What happens if I do nothing?

Getting More Information

21. How do I get more information?

Important Notice Regarding Third-Party Claim Filing Services

22. Important Notice Regarding Third-Party Claim Filing Services