IN THE UNITED STATES DISTRICT COURT
`FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
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`
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`UNITED STATES OF AMERICA
`U.S. Department of Justice
`950 Pennsylvania Avenue NW
`Washington, DC 20530
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`STATE OF NORTH CAROLINA
`114 W. Edenton Street
`Raleigh, NC 27603
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`STATE OF CALIFORNIA
`300 South Spring Street, Suite 1702
`Los Angeles, CA 90013
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`STATE OF COLORADO
`1300 Broadway, 7th Floor
`Denver, CO 80203
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`STATE OF CONNECTICUT
`165 Capitol Avenue
`Hartford, CT 06106
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`STATE OF MINNESOTA
`445 Minnesota Street
`St. Paul, MN 55101
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`STATE OF OREGON
`100 SW Market St
`Portland, OR 97201
`
`STATE OF TENNESSEE
`P.O. Box 20207
`Nashville, TN 37202
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`Case No. 1:24-cv-00710
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`and
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`STATE OF WASHINGTON
`800 Fifth Avenue, Suite 2000
`Seattle, WA 98104-3188,
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`v.
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`Plaintiffs,
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`REALPAGE, INC.
`2201 Lakeside Blvd.
`Richardson, TX 75082,
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`Defendant.
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`COMPLAINT  
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`
`I. 
`II. 
`
`B. 
`
`C. 
`
`D. 
`
`Table of Contents
`Introduction .............................................................................................................. 1 
`RealPage’s Revenue Management Software Is Fueled by Nonpublic, Competitively
`Sensitive Information Shared By Landlords ............................................................ 6 
`Landlords Agree to Share Nonpublic, Competitively Sensitive
`A. 
`Transactional Data with RealPage for Use in Generating Competitors’
`Pricing Recommendations ............................................................................. 7 
`AIRM and YieldStar Users Agree with RealPage to Use the Software
`to Align Pricing ........................................................................................... 11 
`RealPage’s Transactional Data Is Fundamentally Different from Other
`Data Available to Landlords ....................................................................... 13 
`RealPage Revenue Management Software Uses Nonpublic,
`Competitively Sensitive Data to Recommend Prices .................................. 15 
`AIRM and YieldStar Leverage Competitively Sensitive Data to
`1. 
`Generate Price Recommendations ................................................... 15 
`AIRM model training relies on competitively sensitive
`a) 
`data to generate learned parameters. ..................................... 16 
`AIRM and YieldStar incorporate competitors’ nonpublic
`data to generate floor plan price recommendations. ............. 16 
`AIRM and YieldStar use competitors’ nonpublic data—
`including data on future occupancy—to determine unit-
`level prices. ........................................................................... 20 
`LRO Relies Primarily on Landlords to Input Data on Competitors
` .......................................................................................................... 22 
`RealPage Uses Multiple Mechanisms to Increase Compliance with
`Price Recommendations .............................................................................. 23 
`AIRM and YieldStar Make it Easy to Accept Recommendations
`1. 
`and More Difficult and Time-Consuming to Decline ...................... 23 
`RealPage Pushes Clients to Adopt Auto-Accept Settings That
`Automatically Approve Recommendations ..................................... 25 
`RealPage Pricing Advisors Provide a “Check and Balance” on
`Property Managers to Increase Acceptance of Recommendations .. 26 
`Pricing Recommendations Heavily
`Influence Landlords’
`Behavior ........................................................................................... 27 
`III.  Coordination Among Competing Landlords Is a Feature of this Industry ............. 28 
`
`b) 
`
`c) 
`
`E. 
`
`2. 
`
`2. 
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`3. 
`
`4. 
`
`i 
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`2. 
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`3. 
`
`A. 
`B. 
`
`C. 
`
`B. 
`
`C. 
`
`Rental Housing is a Necessity for Millions of Americans .......................... 29 
`The Multifamily Property Industry is Rife with Cooperation Among
`Ostensible Competitors ............................................................................... 29 
`At the Local Level, the Multifamily Property Industry Comprises
`1. 
`a Small Number of Large Landlords Managing Buildings with
`Different Owners .............................................................................. 30 
`Landlords Regularly Discuss Competitively Sensitive Topics
`with Their Competitors and Swap Information ............................... 31 
`At RealPage User Group Meetings, Landlords Discuss
`Competitively Sensitive Topics ....................................................... 35 
`RealPage Uses Nonpublic Information to Allow Landlords to More
`Easily Compare Units on an Apples-to-Apples Basis ................................. 40 
`IV.  RealPage Harms the Competitive Process and Renters By Entering Into Unlawful
`Agreements With Landlords to Share and Exploit Competitively Sensitive
`Data ......................................................................................................................... 40 
`AIRM and YieldStar Have the Purpose and Effect of Distorting the
`A. 
`Competitive Pricing of Apartments ............................................................. 41 
`AIRM and YieldStar Impose Multiple Guardrails Intended to
`Artificially Keep Prices High or Minimize Price Decreases ...................... 49 
`AIRM and YieldStar Harm the Competitive Process by Discouraging
`the Use of Discounts and Price Negotiations .............................................. 53 
`AIRM and YieldStar Increase and Maintain Landlords’ Pricing Power
`by Using Competitors’ Data to Manage Lease Expirations ........................ 54 
`No Procompetitive Benefit Justifies, Much Less Outweighs,
`RealPage’s Use of Competitively Sensitive Data to Align Competing
`Landlords ..................................................................................................... 56 
`RealPage Uses Landlords’ Competitively Sensitive Data To Maintain Its Monopoly
`And Exclude Commercial Revenue Management Software Competitors ............. 56 
`Landlords Are Drawn to RealPage Because of Access to Nonpublic
`A. 
`Transactional Data That Is Used to Increase Landlords’ Revenue ............. 57 
`RealPage’s Collection and Use of Competitively Sensitive Data
`Excludes Competition in Commercial Revenue Management Software .... 59 
`VI.  Relevant Markets .................................................................................................... 62 
`A. 
`Conventional Multifamily Rental Housing Markets ................................... 62 
`1. 
`Product Markets ............................................................................... 62 
`
`D. 
`
`E. 
`
`B. 
`
`V. 
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`ii 
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`a) 
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`b) 
`
`c) 
`
`b) 
`
`2. 
`
`B. 
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`Conventional Multifamily Rentals Are Distinct From
`Other Types of Multifamily Housing .................................... 62 
`Single-Family Housing Is Not A Reasonable Substitute to
`Multifamily Rentals .............................................................. 64 
`Conventional Multifamily Rental Units With Different
`Bedroom Counts Are Relevant Product Markets .................. 66 
`Geographic Markets ......................................................................... 69 
`RealPage-Defined Submarkets Identify Relevant
`a) 
`Geographic Markets .............................................................. 71 
`Core-Based Statistical Areas (CBSAs) Are Relevant
`Geographic Markets .............................................................. 73 
`Commercial Revenue Management Software Market ................................ 76 
`1. 
`Product Market ................................................................................. 77 
`2. 
`Geographic Market ........................................................................... 78 
`Jurisdiction, Venue, and Commerce ....................................................................... 79 
`VII. 
`VIII.  Violations Alleged .................................................................................................. 81 
`IX.  Request for Relief ................................................................................................... 87 
`Appendix A: Submarkets .................................................................................................. 98 
`Appendix B: Submarkets By Bedroom Count ................................................................ 102 
`
`iii 
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`I.
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`INTRODUCTION
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`1.
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`Renters are entitled to the benefits of vigorous competition among
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`landlords. In prosperous times, that competition should limit rent hikes; in harder times,
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`competition should bring down rent, making housing more affordable. RealPage has built
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`a business out of frustrating the natural forces of competition. In its own words, “a rising
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`tide raises all ships.” This is more than a marketing mantra. RealPage sells software to
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`landlords that collects nonpublic information from competing landlords and uses that
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`combined information to make pricing recommendations. In its own words, RealPage
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`“helps curb [landlords’] instincts to respond to down-market conditions by either
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`dramatically lowering price or by holding price when they are losing velocity and/or
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`occupancy. . . . Our tool [] ensures that [landlords] are driving every possible
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`opportunity to increase price even in the most downward trending or unexpected
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`conditions” (emphases added).
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`2.
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`In fact, as RealPage’s Vice President of Revenue Management Advisory
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`Services described, “there is greater good in everybody succeeding versus essentially
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`trying to compete against one another in a way that actually keeps the entire industry
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`down” (emphasis added). As he put it, if enough landlords used RealPage’s software,
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`they would “likely move in unison versus against each other” (emphasis added). To
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`RealPage, the “greater good” is served by ensuring that otherwise competing landlords
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`rob Americans of the fruits of competition—lower rental prices, better leasing terms,
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`more concessions. At the same time, the landlords enjoy the benefits of coordinated
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`pricing among competitors.
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`3.
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`RealPage replaces competition with coordination. It substitutes unity for
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`rivalry. It subverts competition and the competitive process. It does so openly and
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`directly—and American renters are left paying the price.
`
`*****
`Americans spend more money on housing than any other expense. On
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`4.
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`average, American households allocate more than one-third of their monthly income to
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`housing. Some purchase a home, while others choose to, or must, rent. A family’s
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`selection of an apartment reflects a complex set of values and criteria including comfort,
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`safety, access to schools, convenience, and critically, affordability. To ensure they secure
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`the greatest value for their needs, renters rely on robust and fierce competition between
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`landlords.
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`5.
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`RealPage distorts that competition. Across America, RealPage sells
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`landlords commercial revenue management software. RealPage develops, markets, and
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`sells this software to enable landlords to sidestep vigorous competition to win renters’
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`business. Landlords, who would otherwise be competing with each other, submit on a
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`daily basis their competitively sensitive information to RealPage. This nonpublic,
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`material, and granular rental data includes, among other information, a landlord’s rental
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`prices from executed leases, lease terms, and future occupancy. RealPage collects a broad
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`swath of such data from competing landlords, combines it, and feeds it to an algorithm.
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`2 
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`6.
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`Based on this process and algorithm, RealPage provides daily, near real-
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`time pricing “recommendations” back to competing landlords. These recommendations
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`are based on the sensitive information of their rivals. But these are more than just
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`“recommendations.” Because, in its own words, a “rising tide raises all ships,” RealPage
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`monitors compliance by landlords to its recommendations. RealPage also reviews and
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`weighs in on landlords’ other policies, including trying to—and often succeeding in—
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`ending renter-friendly concessions (like a free month’s rent or waived fees) to attract or
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`retain renters. A significant number of landlords then effectively agree to outsource their
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`pricing function to RealPage with auto acceptance or other settings such that RealPage as
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`a middleman, and not the free market, determines the price that a renter will pay.
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`Competing landlords choose to share their information with RealPage to “eliminate the
`
`guessing game” about what their competitors are doing and ultimately take instructions
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`from RealPage on how to make business decisions to “optimize”—or in reality,
`
`maximize—rents.
`
`7.
`
`Each landlord pays steep fees to license RealPage’s software. RealPage’s
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`stated goals and value proposition are not a secret. Its executives are blunt: They want
`
`landlords to “avoid the race to the bottom in down markets.” Sometimes RealPage is
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`even more direct, acknowledging that its software is aimed at “driving every possible
`
`opportunity to increase price” or observing that among landlords, “there is a greater good
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`in everybody succeeding versus essentially trying to compete against one another in a
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`way that actually keeps the entire industry down.”
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`3 
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`8.
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`But that is not how the free market works. A free market requires that
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`landlords compete on the merits, not coordinate pricing. Landlords should win renters by
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`offering whatever combination of price and quality they think is most attractive. For
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`example, landlords could lower rents or provide other financial concessions, like free
`
`months of rent, or with investments in amenities like gyms, grilling areas, or pools. Put
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`differently, the fear of losing a renter to a competitor should motivate rival landlords to
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`compete vigorously.
`
`9.
`
`RealPage’s revenue management software ingests on a daily basis
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`nonpublic rental rates, future apartment availability, and changes in competitors’ rates
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`and occupancy. As competitor-landlords increase their rents, RealPage’s software nudges
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`other competing landlords to increase their rents as well. RealPage calls this
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`“maximiz[ing] opportunity[.]” As RealPage explained to one landlord, by using
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`competitors’ data, they can identify situations where “we may have a $50 increase instead
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`of a $10 increase for that day.” This is what RealPage encourages as “stretch and pull
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`pricing.”
`
`10. RealPage allows landlords to manipulate, distort, and subvert market
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`forces. One landlord observed that RealPage’s software “can eliminate the guessing
`
`game” for landlords’ pricing decisions. Discussing a different RealPage product, another
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`landlord said: “I always liked this product because your algorithm uses proprietary data
`
`from other subscribers to suggest rents and term. That’s classic price fixing . . . .” A third
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`landlord explained, “Our very first goal we came out with immediately out of the gate is
`
`4 
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`that we will not be the reason any particular sub-market takes a rate dive. So for us our
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`strategy was to hold steady and to keep an eye on the communities around us and our
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`competitors.”
`
`11. RealPage’s scheme not only distorts competition to the detriment of renters,
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`but also allows it to reinforce its dominant position in the market for commercial revenue
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`management software. By its own account, RealPage controls at least 80 percent of that
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`market. Its dominant position is protected by substantial data advantages due to its
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`massive reservoir of ill-gotten competitively sensitive information from competing
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`landlords. No other revenue management company can match RealPage’s access to
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`landlords’ nonpublic, competitively sensitive rental data. This is why RealPage
`
`acknowledges that it “does not have any true competitors, mainly because our data is
`
`based on real lease transaction data.” RealPage’s conduct is predatory and exclusionary,
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`which has allowed it to distort the market opportunities for honest providers of revenue
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`management software.
`
`12. At bottom, RealPage is an algorithmic intermediary that collects, combines,
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`and exploits landlords’ competitively sensitive information. And in so doing, it enriches
`
`itself and compliant landlords at the expense of renters who pay inflated prices and
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`honest businesses that would otherwise compete.
`
`13.
`
`The United States and the States of North Carolina, California, Colorado,
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`Connecticut, Minnesota, Oregon, Tennessee, and Washington, acting by and through
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`their respective Attorneys General, bring this action pursuant to Sections 1 and 2 of the
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`5 
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`Sherman Act to rid markets of (i) RealPage’s unlawful information-sharing scheme, and
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`(ii) its illegal monopoly in commercial revenue management software. In so doing,
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`Plaintiffs seek to restore the free market to deserving individuals, families, and honest
`
`businesses.
`
`II. REALPAGE’S REVENUE MANAGEMENT SOFTWARE IS FUELED
`BY NONPUBLIC, COMPETITIVELY SENSITIVE INFORMATION
`SHARED BY LANDLORDS
`
`14. RealPage dominates the market for commercial revenue management
`
`software that landlords use to price apartments, controlling at least 80 percent of that
`
`market, according to its own estimates. RealPage currently offers three revenue
`
`management systems to landlords: YieldStar, AI Revenue Management (AIRM), and
`
`Lease Rent Options (LRO). The company’s main legacy software, YieldStar, is the
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`product of three acquisitions and subsequent internal development. Its successor, AIRM,
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`uses much of the same codebase as YieldStar, but RealPage claims that AIRM’s refined
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`models and forecasting are more precise. RealPage acquired its other revenue
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`management software, LRO, in 2017. RealPage has made plans to sunset both YieldStar
`
`and LRO by the end of 2024.
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`15. Competitively sensitive data collected from competing landlords is a
`
`critical input to RealPage’s revenue management software. AIRM and YieldStar collect
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`this data, such as rental applications, executed new leases, renewal offers and
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`acceptances, and forward-looking occupancy, and use it to generate price
`
`6 
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`recommendations for the competing landlords. This information is among the most
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`competitively sensitive data a landlord maintains.
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`16.
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`The exploitation of sensitive data from competing landlords is central to
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`RealPage’s approach. As part of pitching its software to landlords, RealPage highlights
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`that its pricing algorithms use their competitors’ data sourced directly from “lease
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`transaction data.” RealPage describes this nonpublic data from competitors as one of
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`three “building blocks of price” in AIRM and YieldStar. Landlords thus share their
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`competitively sensitive information with RealPage with the understanding that
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`RealPage’s software will use the data to generate recommendations for rivals (and vice
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`versa).
`
`A. Landlords Agree to Share Nonpublic, Competitively Sensitive
`Transactional Data with RealPage for Use in Generating Competitors’
`Pricing Recommendations
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`17. RealPage amasses nonpublic, competitively sensitive data from competing
`
`landlords through use of its pricing algorithms, other rental property software, and
`
`thousands of monthly phone calls. The combined troves of nonpublic, competitively
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`sensitive data are much more granular, sensitive, timely, and comprehensive than
`
`alternatives—and far more detailed than any data publicly available to potential renters.
`
`RealPage then uses this data in generating competitors’ pricing recommendations.
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`18. Data shared through YieldStar and AIRM. Each AIRM and YieldStar
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`client agrees to share detailed data with RealPage that are private, updated nightly, and
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`granular. The data include lease-level information on each unit’s effective rent (rent net
`
`7 
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`of discounts), rent discounts, rent term, and lease status, as well as unit characteristics
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`such as layout and amenities. It also includes the number of potential future renters who
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`have visited a property or submitted a rental application.
`
`19.
`
`Landlords understand that AIRM and YieldStar use their data to
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`recommend prices not just for their own units, but also for competitors. For example, a
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`revenue management director at Landlord 1 testified that she understood that Landlord 1,
`
`and other competing landlords who used AIRM or YieldStar, agreed with RealPage to
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`share their data, which was combined in a single data pool for use by YieldStar and
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`AIRM. An executive at Landlord 2 noted the advantages to using YieldStar at a property
`
`if others in the property’s submarket—the small geographic area around the property—
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`also used YieldStar because “the shared data between the models at different
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`communities can be a benefit in getting accurate transactional data on a timely basis.”
`
`20.
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`Landlords agree to provide this information for use by their competitors
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`because they understand they will be able to leverage the sensitive information of their
`
`rivals in turn. In its pitch to prospective clients, RealPage describes AIRM’s and
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`YieldStar’s access to competitors’ granular, transactional data as a meaningful tool that it
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`claims enables landlords to outperform their properties’ competitors by 2–7%. RealPage
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`clients receive training that highlights the role of competitors’ transactional data in the
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`price recommendation process.
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`21. Data Shared Through Other RealPage Products. AIRM and YieldStar are
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`not the only ways that RealPage shares nonpublic, competitively sensitive information
`
`8 
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`among landlords. RealPage obtains the same confidential transactional data from
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`landlords that license at least three other programs: OneSite, Performance Analytics with
`
`Benchmarking, and Business Intelligence.
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`22. OneSite is RealPage’s property management software, which operates as
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`the central source of data for landlords’ leasing activity. Performance Analytics with
`
`Benchmarking allows landlords to compare the performance of their properties and floor
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`plans (e.g., a one-bedroom, one-bathroom unit) to their competitors. Business Intelligence
`
`is a data analytics tool that pulls data from a landlord’s property management software
`
`and other products.
`
`23.
`
`Each landlord using RealPage’s OneSite, Business Intelligence, and
`
`Performance Analytics with Benchmarking products agrees to share its proprietary data
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`with RealPage and agrees that RealPage’s revenue management software can use the data
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`to generate pricing recommendations. The license agreements for these products
`
`specifically identify the shared data, such as pricing information, as confidential,
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`nonpublic information. RealPage takes this deeply confidential information and uses it to
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`provide rent recommendations to competitors of these clients.
`
`24.
`
`These agreements grant RealPage access to confidential information from
`
`over 16 million units across the country, including many that do not use its revenue
`
`management products. With respect to Performance Analytics with Benchmarking alone,
`
`a RealPage sales representative told a prospective client that “we have over 16 million
`
`units of data coming from various source operating systems (PMS) [property
`
`9 
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`management software] into the PAB platform,” making RealPage the top choice for
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`“transactional data benchmarking.” With properties containing approximately 3 million
`
`units using AIRM and YieldStar, these additional agreements meaningfully multiply the
`
`scale of the transactional data used by AIRM and YieldStar. This gives RealPage greater
`
`visibility, including into markets with less penetration by AIRM and YieldStar, granting
`
`even initial AIRM and YieldStar adopters in a new market the benefit of access to a
`
`significant amount of nonpublic, competitively sensitive information.
`
`25.
`
`Landlords understand that AIRM and YieldStar will use data from these
`
`products. A revenue management director at Landlord 1 explained that RealPage ingests
`
`transactional data from several RealPage products, besides AIRM and YieldStar, for use
`
`in revenue management.
`
`26. A revenue management executive at Landlord 2 asked RealPage if other
`
`specific landlords were using RealPage’s non-revenue management products. The
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`landlord’s owner client was concerned about the data available to YieldStar because
`
`competing properties were unsophisticated and did not use revenue management. This
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`executive wanted to confirm that “YieldStar will be able to leverage actual transactional
`
`data behind the scenes and not just look at offered rents for their comps.” RealPage
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`reminded the Landlord 2 executive that RealPage collected transactional data for all users
`
`of OneSite, Business Intelligence, and Performance Analytics with Benchmarking, and
`
`reassured the executive that YieldStar had ample transactional and survey data for that
`
`area.
`
`10 
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`27. Calling Landlords. RealPage has an additional, complementary product
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`called Market Analytics. Market Analytics compiles data from over 50,000 monthly
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`phone calls that RealPage makes to landlords across the country. On these calls RealPage
`
`collects nonpublic, competitively sensitive information by floor plan on occupancy rates,
`
`effective rents, and concessions, as well as information on the owner, management
`
`company, and any revenue management software used at the property. These market
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`surveys cover over 11 million units and approximately 52,000 properties. Landlords,
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`including but not limited to those that use AIRM, YieldStar, or other RealPage products,
`
`knowingly share this nonpublic information with RealPage.
`
`B. AIRM and YieldStar Users Agree with RealPage to Use the Software to
`Align Pricing
`
`28.
`
`In addition to agreeing to share nonpublic, competitively sensitive data with
`
`RealPage, each AIRM and YieldStar licensee agrees with RealPage to use the AIRM or
`
`YieldStar pricing software as RealPage designed it. Landlords are expected to review
`
`daily AIRM or YieldStar floor plan price recommendations and use the programs to set
`
`scheduled floor plan rents or even unit-level prices.
`
`29. While landlords may not accept every price recommendation, they use
`
`AIRM or YieldStar as their pricing software, regularly review AIRM or YieldStar floor
`
`plan recommendations, use AIRM or YieldStar to set a scheduled floor plan rent, and use
`
`AIRM or YieldStar to set unit-level prices.
`
`30.
`
`Landlords who use AIRM and YieldStar know that others are using the
`
`same software. Some landlords track which revenue management software their
`
`11 
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`competitors use, including by contacting competing properties directly and exchanging
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`nonpublic information. Other landlords, including prospective AIRM and YieldStar
`
`users, ask RealPage whether there are existing AIRM and YieldStar users nearby before
`
`they themselves license the products.
`
`31. An executive at Landlord 2, for example, explained to her team how she
`
`would learn from RealPage data or from a property’s website whether a property used
`
`revenue management. This information is important because properties that use revenue
`
`management tend to update prices much more frequently, and so a landlord will react
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`differently to those price changes if it knows the competitor is using revenue
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`management.
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`32. RealPage frequently tells prospective and current clients that a “rising tide
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`raises all ships.” A RealPage revenue management vice president explained that this
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`phrase means that “there is greater good in everybody succeeding versus essentially
`
`trying to compete against one another in a way that actually keeps the industry down.”
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`This rising tide lifts all landlords, including but not limited to AIRM and YieldStar users.
`
`33.
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`In using AIRM and YieldStar, landlords expect this pricing alignment and
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`use RealPage software in part for this reason. One landlord echoed the RealPage
`
`executive, using the phrase “a rising tide rises [sic] all ships” to explain that AIRM would
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`move prices in a “similar manner” to how the top and bottom of the market move.
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`Elsewhere that same landlord noted that “if everyone in the market is doing well and
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`everyone in the market has [sic] is having the rates go up, so should ours, right?” An
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`employee at Landlord 2 referenced RealPage’s use of the phrase “a rising tide raises all
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`ships” to explain how AIRM would provide price recommendations that amplify market
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`trends. Multiple landlords have expressed their preference that their competitors use
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`YieldStar and AIRM because widespread use would benefit them all. An executive of
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`one landlord (which itself uses YieldStar and AIRM) said in a 2021 earnings call that
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`more sophisticated, “high-quality competition” was better for that landlord when “they all
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`use revenue management. They are all smart. They raised rents when they should.”
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`C. RealPage’s Transactional Data Is Fundamentally Different from Other
`Data Available to Landlords
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`34.
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`The data that RealPage uses and supplies is unique relative to public data
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`available to landlords on listing or property websites. As compared to public data,
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`RealPage data is much more granular, covers a broader array of business information,
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`and includes competitively sensitive data across several dimensions. For example:
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` Information on Actual Transactions. RealPage’s data include, for each
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`lease, the unit, floor plan, listed rent, final transacted lease price (including
`
`any discounts), and lease term.
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` Renewals. RealPage’s data include the same information for lease renewals.
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`Information on renewals is not listed publicly—not even asking rents—
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`leaving a significant blind spot for landlords not using RealPage.
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` Time Span. AIRM and YieldStar have access to current and historical lease
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`data, from the previous day and going back two to three years.
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` Future Demand. The shared data further include information on tenant
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`demand, including detailed information on inquiries and applications by
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`potential future tenants.
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` Accuracy. Landlords have greater assurance of the accuracy of the data
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`because it comes directly from the landlords’ own databases.
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` Coverage. The RealPage data covers millions of units from users of its
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`revenue management software and other products.
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`35. RealPage touts how its data is different. As one RealPage pitch deck put it,
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`“we have [the] most data and the best data.” And the “[q]uality of data is best in class
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`given that it is ‘lease transaction data’—this provides insight into performance data from
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`actual signed leases, both new and renewal, net effective of concessions.” Another noted
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`that without YieldStar “you’ll be pricing your renewals in the dark without insight into
`
`actual lease transaction data that YS uses to help you make pricing decisions. This is
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`critical to price renewals right[,] especially in a downturn.”
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`36. Access to this data proves important in winning over revenue management
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`clients, including skeptical ones. One RealPage senior manager noted that a “highly
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`suspicious CFO” was won over in part by YieldStar’s “lease transaction data” that
`
`allowed his company to “achieve what his people couldn’t achieve on their own.”
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`37. Another landlord’s internal training presentation on YieldStar highlighted
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`the importance of having access to competitors’ transactional data:
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`Case 1:24-cv-00710 Document 1 Filed 08/23/2