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`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF TENNESSEE
`NASHVILLE DIVISION
`
` Case No. 3:23-md-3071
`MDL No. 3071
`
`Judge Waverly D. Crenshaw, Jr.
`This document relates to:
`Navarro v. RealPage, Inc., et al.,
`No. 3:23-cv-00329
`
`AMENDED CLASS ACTION COMPLAINT
`
`
`JURY TRIAL DEMANDED
`
`
`Plaintiffs,
`
` Defendants.
`
`RACHEL MEREDITH, BENJAMIN
`DEMPSEY, ASHLEY NELSON, MIA
`LAUDER, AND IVONNE ARRIOLA
`MENDIETA, Individually and on Behalf of
`All Others Similarly Situated,
`
`
`
`
`
`REALPAGE, INC.; GREYSTAR REAL
`ESTATE PARTNERS, LLC; BH
`MANAGEMENT SERVICES, LLC;
`CAMPUS ADVANTAGE, INC.;
`CARDINAL GROUP HOLDINGS LLC; CA
`VENTURES GLOBAL SERVICES, LLC;
`D.P. PREISS COMPANY, INC.;
`UNIVERSITY HOUSE COMMUNITIES
`LLC; CARMEL PARTNERS LLC;
`TIMBERLINE REAL ESTATE
`VENTURES LLC; B.HOM STUDENT
`LIVING LCC; JOHN DOES 1-10,
`
`
`
`
`
`AMENDED CLASS ACTION COMPLAINT
`Case No. 3:23-md-3071
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`
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`
`

`

`I. 
`
`II. 
`
`III. 
`
`IV. 
`
`TABLE OF CONTENTS
`
`Page
`NATURE OF THE ACTION ..............................................................................................1 
`
`PARTIES .............................................................................................................................6 
`
`JURISDICTION AND VENUE ........................................................................................10 
`
`FACTUAL BACKGROUND ............................................................................................11 
`
`A. 
`
`B. 
`
`RealPage’s revenue management software is widely used in the
`student housing market ..........................................................................................11 
`
`RealPage and Lessor Defendants conspired to eliminate
`competition in the student housing market by effectively
`outsourcing price and supply decisions to a common decision
`maker......................................................................................................................20 
`
`C. 
`
`Defendants monitor and enforce compliance with the scheme .............................29 
`
` 
`
` 
`
`F. 
`
`The market for student housing real estate leases is distinct from
`the multifamily market ...........................................................................................34 
`
`“Plus Factors” indicate the market for student housing real estate
`leases is susceptible to the formation, maintenance, and efficacy of
`a cartel ....................................................................................................................50 
`
`High barriers to entry .................................................................................50 
`1. 
`High barriers to exit ...................................................................................51 
`2. 
`Inelastic demand ........................................................................................51 
`3. 
`High concentration .....................................................................................52 
`4. 
`Fungibility of demand ................................................................................54 
`5. 
`Frequent exchanges of competitively sensitive information .....................54 
`6. 
`Opportunities to collude and extensive evidence of collusion ...................55 
`7. 
`Defendants’ conduct has had extensive anticompetitive effects ............................58 
`
`1. 
`
`2. 
`
`Lessor Defendants’ use of RealPage has driven student rents to record
`highs ...........................................................................................................58 
`Government regulators have expressed concerns about algorithmic
`pricing’s effect on competition ..................................................................60 
`The conspiracy has caused vulnerable students to languish while the
`Defendants flourished ................................................................................61 
`AMENDED CLASS ACTION COMPLAINT - i
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`3. 
`
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`

`

`V. 
`
`RELEVANT MARKET.....................................................................................................64 
`
`A. 
`
`B. 
`
`The relevant product market is the market for the least of student
`housing real estate ..................................................................................................64 
`
`Regional submarkets ..............................................................................................65 
`
`Austin, TX..................................................................................................66 
`1. 
`Tallahassee, FL ..........................................................................................66 
`2. 
`Columbia, SC .............................................................................................67 
`3. 
`Knoxville, TN ............................................................................................67 
`4. 
`Eugene, OR ................................................................................................67 
`5. 
`Auburn, AL ................................................................................................67 
`6. 
`Gainesville, FL ...........................................................................................68 
`7. 
`Greenville, NC ...........................................................................................68 
`8. 
`Baton Rouge, LA .......................................................................................68 
`9. 
`Champaign, IL ...........................................................................................69 
`10. 
`Athens, GA ................................................................................................69 
`11. 
`State College, PA .......................................................................................69 
`12. 
`College Station, TX ...................................................................................69 
`13. 
`Huntsville, TX............................................................................................70 
`14. 
`Chapel Hill, NC .........................................................................................70 
`15. 
`Tuscaloosa, AL ..........................................................................................70 
`16. 
`17.  Madison, WI ..............................................................................................70 
`18.  Wilmington, NC .........................................................................................71 
`19. 
`San Antonio, TX ........................................................................................71 
`20. 
`Seattle, WA ................................................................................................71 
`21. 
`Norman, OK ...............................................................................................72 
`22. 
`College Park, MD ......................................................................................72 
`23. 
`New Haven, CT .........................................................................................72 
`24.  West Lafayette, IN .....................................................................................72 
`
`AMENDED CLASS ACTION COMPLAINT - ii
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`East Lansing, MI ........................................................................................73 
`25. 
`Bloomington, IN ........................................................................................73 
`26. 
`Blacksburg, VA..........................................................................................73 
`27. 
`Greensboro, NC .........................................................................................73 
`28. 
`Arlington, TX .............................................................................................74 
`29. 
`Louisville, KY............................................................................................74 
`30. 
`Clemson, SC ..............................................................................................74 
`31. 
`Fort Collins, CO .........................................................................................74 
`32. 
`Pullman, WA ..............................................................................................75 
`33. 
`Lubbock, TX ..............................................................................................75 
`34. 
`FRAUDULENT CONCEALMENT ..................................................................................75 
`
`VI. 
`
`VII.  CLASS ACTION ALLEGATIONS ..................................................................................76 
`
`VIII.  CLAIMS FOR RELIEF .....................................................................................................77 
`
`FIRST CLAIM FOR RELIEF: VIOLATION OF SECTION 1 OF THE
`SHERMAN ACT FOR AGREEMENT IN RESTRAINT OF TRADE
`15 U.S.C. § 1 ......................................................................................................................77 
`
`SECOND CLAIM FOR RELIEF: VIOLATION OF SECTION 1 OF THE
`SHERMAN ACT FOR CONSPIRACY TO EXCHANGE
`COMPETITIVE INFORMATION 15 U.S.C. § 1 .............................................................78 
`
`THIRD CLAIM FOR RELIEF: VIOLATION OF STATE ANTITRUST
`STATUTES........................................................................................................................80 
`
`REQUEST FOR RELIEF ..............................................................................................................98 
`
`JURY TRIAL DEMANDED .........................................................................................................99 
`
`
`
`AMENDED CLASS ACTION COMPLAINT - iii
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`Plaintiffs Rachel Meredith, Benjamin Dempsey, Ashley Nelson, Mia Lauder, and Ivonne
`Arriola Mendieta bring this action on behalf of themselves individually and on behalf of a class
`consisting of all persons who leased student housing properties directly from any Lessor
`Defendant or Co-Conspirator from January 1, 2010 through the present. Plaintiffs bring this
`action for treble damages and injunctive relief under Section 1 of the Sherman Act. Plaintiffs
`demand a trial by jury.
`
`I.
`NATURE OF THE ACTION
`1.
`Plaintiffs challenge an unlawful agreement among lessors of student housing
`properties (“Lessors”) to artificially inflate the prices of student housing across the United States,
`including near college campuses.
`2.
`Property managers within the real estate industry recognize the market for student
`housing as distinct from the market for traditional apartments—what the industry calls
`multifamily housing—and in fact manage or build large volumes of so-called “purpose-built”
`housing, i.e., housing designed specifically for students.1 Students are a captive market: they
`need to live near the school campus, and they often have less time to make a rental choice
`because the leasing cycle for student housing is tied to the academic year. Student housing leases
`often rent per bed, rather than on a per square foot basis. Leases usually run between nine and
`twelve months.2
`3.
`Large property managers, including the Defendant Lessors, manage student
`housing properties near many college campuses across the United States. In a competitive
`market, these companies would compete with one another to attract student renters and maximize
`
`
`1 See, e.g., Campus Advantage, What is Purpose-Built Student Housing? (February 21,
`2018), available at https://campusadv.com/purpose-built-student-housing/ (“Purpose-built
`student housing is an apartment community designed for residents in higher education. These
`communities offer amenities tailored to college students, such as individual leases, study areas,
`fully furnished units, and roommate matching. They’re typically located near a college campus
`and may offer unique residence life programs, such as Students First™, and employ students to
`act as community assistants, providing support to their fellow student residents. College
`campuses are like small cities in themselves, where students live, study, and work all in the same
`area. This campus-centric lifestyle drives a need for a different kind of housing – one that is not
`typically fulfilled by conventional housing options.”).
`2 ORG Portfolio Management, Student Housing: An Attractive Alternative to Multifamily
`(March 28, 2022), available at https://irei.com/wp-content/uploads/2022/05/Student-Housing-
`Thought-Piece-Final.pdf.
`AMENDED CLASS ACTION COMPLAINT - 1
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`occupancy of their properties. Indeed, this is what they used to do: before implementing
`Defendant RealPage, Inc. (“RealPage”)’s “Revenue Management” software, competing lessors
`would try to maximize occupancy by keeping rent competitive and/or offering concessions (e.g.,
`a free month of rent) and giveaways (e.g., raffle prizes or gift cards3).
`4.
`But this is no longer the case. RealPage introduced its Revenue Management
`program specifically within the context of student housing. The Defendant Lessors used this this
`program to stop making independent pricing and supply decisions.
`5.
`RealPage is a company that collects real-time pricing and supply levels from its
`participants. Each month, participants give RealPage data on pricing, concessions, and other
`information for their own properties, as well as the information the participants may have
`gathered about their competitors. RealPage compiles this data into a common algorithm that
`sends the participants forward-looking, unit-specific pricing and supply recommendations based
`on their shared data.
`6.
`Lessors agreed to follow these recommendations, on the expectation that
`competing Lessors would do the same. As Adam Byrley, COO of Defendant D.P. Preiss
`Company has stated, because the industry is so competitive, “we absolutely have to have a
`software and technology provider that allow us to be above and beyond the rest of the market
`and specific to students.”4 RealPage recommends that participants accepts its recommended
`prices, and closely monitors compliance—going so far as to request that housing managers
`justify, in writing, deviations from RealPage’s recommended pricing. Indeed, it even employs so
`called “Pricing Advisors,” or “revenue management advisors,” who oversee and closely monitor
`lessors’ compliance with RealPage’s recommended rates. On its website, for instance, RealPage
`touts that its advisors “[r]review pricing daily or weekly in collaboration with on-site and
`
`
`3 Julia Bunch, A Breakdown of Student Housing Giveaways, RealPage Analytics (June 7,
`2021), available at https://www.realpage.com/analytics/breakdown-student-housing-giveaways/
`(last visited June 14, 2023).
`4 RealPage Student Leasing Helps the Preiss Company Grow and Compete, RealPage
`Videos, https://www.realpage.com/videos/student-leasing-helps-preiss-compete/ (video) (last
`visited June 14, 2023).
`AMENDED CLASS ACTION COMPLAINT - 2
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`regional operations management” and “[m]onitor and report on weekly rents, occupancy, and
`revenue trends.”5
`7.
`RealPage provided the platform and the algorithm for collusion, which granted
`Lessors the unprecedented ability to “[f]acilitate collaboration among operations”6 and “track
`your competition’s rent with precision.”7 Lessors submitted to RealPage data that is “as fine and
`granular as bits of sand,”8 including rents charged for each unit and each floor plan, lease terms,
`amenities, move-in and move-out dates. RealPage takes this data—“literally hundreds of
`variables,” according to founder and former CEO Steve Winn9—and recommends a price for
`each unit that a lessor owns, giving the lessor the courage to charge an inflated price with the
`implicit assurance that all of their competitors will do the same.
`8.
`In a presentation at the 2014 National Apartment Association Student Housing
`Conference & Exposition, RealPage explained that its revenue management tool “utilizes the
`competitive data” by “[c]omparing the effective rent you achieve to the top and bottom of the
`competitive range for your selected competitors.”10 RealPage even gave a sneak peek of the
`dashboard that property managers have access to, which included a view by competitor11:
`
`
`5 “RealPage AI Revenue Management”, RealPage, available at
`https://www.realpage.com/asset-optimization/revenue-management/ (last visited June 9, 2023).
`6 Keith Dunkin, Driving Outperformance: Ensuring Success with Revenue Management
`(March 2014), available at https://www.naahq.org/sites/default/files/naa-
`documents/meetings/student-housing/D1-Ensuring-your-success.pdf (last visited June 14, 2023).
`7 YieldStar Revenue Management Overview Presentation, Realpage Videos, available at
`https://www.realpage.com/videos/revenue-management-software-oveview-sop/ (last visited June
`14, 2023).
`8 How YieldStar Can Double & Triple Revenue Performance, RealPage Videos, available at
`https://www.realpage.com/videos/yieldstar-helps-top-nmhc-companies/ (last visited Nov. 2,
`2022).
`9 RealPage, Inc. Q2 2020 Earnings Conference Call (July 30, 2020), available at
`https://seekingalpha.com/article/4363323-realpages-rp-ceo-steve-winn-on-q2-2020-results-
`earnings-call-
`transcript?open_reset_password=true&origin=confirm_registration&utm_campaign=%7Cconfir
`mation_link_registration&utm_medium=email&utm_source=seeking_alpha.
`10 Keith Dunkin, Driving Outperformance: Ensuring Success with Revenue Management
`(March 2014), available at https://www.naahq.org/sites/default/files/naa-
`documents/meetings/student-housing/D1-Ensuring-your-success.pdf (last visited June 14, 2023).
`11 Id.
`AMENDED CLASS ACTION COMPLAINT - 3
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`9.
`RealPage emphasized in presentations that it had designed specific revenue
`management tools customized for the student housing market12:
`
`
`
`10.
`Consistent with the specific needs of the student housing market, RealPage
`provided pricing information for Lessor Defendants that allowed them to closely analyze their
`pricing in comparison to their competitors at a bedroom-by-bedroom level:
`
`
`
`
`
`12 Id.
`AMENDED CLASS ACTION COMPLAINT - 4
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`
`
`11.
`Similarly, in 2012, a company named Rainmaker Group launched a revenue
`management program called “LRO Student” that was specifically designed for the student
`housing market.13 LRO Student took into account the unique aspects of the student housing
`market in projecting prices, including the fact (a) that individual units are often leased by bed
`and (b) that tenants are limited in the number of times they will renew before they graduate.
`Competitors would input property data and their competitive environments. The application’s
`pricing engine would then use the data input by multiple users to calculate the best price for the
`market and would provide users with updated prices on a daily basis.14 The LRO assets of
`Rainmaker Group were subsequently acquired by RealPage for $300 million in 2017.15
`12.
`Together, RealPage and Lessors have successfully driven rents higher for students
`across the county, and boasted about the impact of their collusion. In a press release, RealPage
`stated its revenue management software yielded a 2% to 7% revenue outperformance in the
`
`
`13 The Price is Right, Student Housing Business (Feb. 22, 2023), available at
`https://studenthousingbusiness.com/the-price-is-right/ (last visited June 14, 2023).
`14 Id.
`15 Donovan Jones, RealPage to Acquire Rainmaker Group Multifamily LRO Assets, Seeking
`Alpha (Mar. 9, 2017), available at https://seekingalpha.com/article/4053859-realpage-to-acquire-
`rainmaker-group-multifamily-lro-assets.
`AMENDED CLASS ACTION COMPLAINT - 5
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`market.16 One Lessor Defendant, Greystar, stated in a video testimonial on RealPage’s website
`that “over the last 10 years, spanning about 150 projects, the services that [RealPage] provided
`have equated to a return on investment of about 300% on about 90% of those projects.”17 In a
`joint case study between RealPage and Lessor Defendant Campus Advantage, Campus
`Advantage reported outperforming the market by 14.1% “with a negative YoY occupancy
`change.”18 RealPage advised property owners and potential clients: “If you want to outperform
`the market term after term, focus less on occupancy and more on strategic lease pricing.”
`Campus Advantage had “below average occupancy rates,” yet still outperformed the market by
`double digits. Each of Campus Advantages’ properties “implemented a premium revenue
`management solution with exclusive student housing market research and reporting . . . The real-
`time accessibility of this data was critical to widening the margins for above market
`performance.”19
`13.
`The conspiracy Plaintiffs and members of the Class challenge is unlawful under
`Section 1 of the Sherman Act and state law. Plaintiffs bring this action to recover treble damages
`as well as injunctive and other appropriate relief on behalf of all others similarly situated.
`II.
`PARTIES
`14.
`Plaintiff Rachel Meredith is a resident of the State of Alabama and a student at
`Auburn University. Plaintiff Meredith rented a multifamily residential unit at UNCOMMON
`Auburn, located at 250 W Glenn Ave, Auburn, AL beginning in August 2021 through the
`present. The property is operated by Lessor Conspirator CA Ventures Global Services, LLC in
`Auburn, Alabama. Plaintiff Meredith has paid higher rent as a result of Defendants’ conspiracy.
`
`
`16 Press Release, RealPage, RealPage Hosts Executive Student Summit (May 8, 2019),
`https://www.realpage.com/news/realpage-hosts-executive-student-summit/ (last visited Nov. 2,
`2022).
`17 RealPage Consulting Helps Greystar Succeed in the Student Housing Industry, RealPage
`Videos, available at https://www.realpage.com/videos/student-housing-software-review-greystar/
`(last visited June 14, 2023).
`18 Student Housing: Revenue Management Case Study, RealPage Case Studies, available at
`https://www.realpage.com/case-studies/campus-advantage-revenue-management-case-
`study/?utm_source=campus-
`advantage&utm_medium=bp&utm_campaign=pmi&utm_term=20181003 (last visited June 14,
`2023).
`19 Id.
`AMENDED CLASS ACTION COMPLAINT - 6
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`15.
`Plaintiff Benjamin Dempsey is a resident of the State of Alabama and was a
`student at Auburn University. Plaintiff Dempsey rented a purpose built student housing unit at
`The Beacon, located at 1255 S. College Street, Auburn, AL beginning in the Fall of 2015
`through the Spring of 2017. The property is operated by Lessor Defendant Campus Advantage
`Inc., in Auburn, Alabama. Plaintiff Dempsey has paid higher rent as a result of Defendants’
`conspiracy.
`16.
`Plaintiff Ashley Nelson is a resident of the State of North Carolina and a student
`at East Carolina University. Plaintiff Nelson rented a purpose built student housing unit at
`University Edge and Dickinson Lofts, located at 550 Pitt, N Greene St, Greenville, North
`Carolina beginning in August 2021 through July 2022. The property is operated by Lessor
`Defendant Cardinal Group Holdings LLC, in Greenville, North Carolina. Plaintiff Nelson has
`paid higher rent as a result of Defendants’ conspiracy.
`17.
`Plaintiff Mia Lauder is a resident of the State of Oregon and a student at the
`University of Oregon. Plaintiff Lauder rented a purpose built student housing unit at The Soto,
`located at 1180 Patterson St, Eugene, Oregon in August 2022 through the present. The property
`is operated by Lessor Defendant Campus Advantage Inc., in Eugene, Oregon. Plaintiff Lauder
`has paid higher rent as a result of Defendants’ conspiracy.
`18.
`Plaintiff Ivonne Arriola Mendieta is a resident of the State of Florida and was a
`student at Florida State University. Plaintiff Mendieta rented a purpose built student housing unit
`at The Osceola located at 500 Chapel Dr, Tallahassee, Florida beginning in May 2016 through
`July 2016. The property is operated by Defendant Conspirator Cardinal Group Holdings LLC, in
`Tallahassee, Florida. Plaintiff Mendieta has paid higher rent as a result of Defendants’
`conspiracy.
`19.
`Defendant RealPage, Inc. is a Delaware corporation headquartered in Richardson,
`Texas. RealPage provides software and services to the residential real estate industry, including
`the revenue management software described herein.
`20.
`Lessor Defendant Greystar Real Estate Partners, LLC (“Greystar”) is a Delaware
`limited liability corporation headquartered in Charleston, South Carolina. It is the largest
`AMENDED CLASS ACTION COMPLAINT - 7
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`manager of multifamily rental real estate in the United States, and the fourth largest student
`housing manager in the United States.20 It manages over 100,000 student beds globally, serves
`more than 80 universities, and manages $17.3 billion in student housing assets.21 Greystar is one
`of RealPage’s clients and uses its revenue management software.
`21.
`Lessor Defendant BH Management Services, LLC is a Florida limited liability
`corporation headquartered in Des Moines, Iowa. BH Management Services was combined with
`another student housing property management company, Campus Evolution Villages, in 2020 to
`form B.HOM Student Living. B.HOM Student Living is the fourteenth largest student housing
`manager in the United States 22 and manages over 30,000 beds across 40+ universities.23 B.HOM
`Student Living was also one of RealPage’s clients and uses its revenue management software.
`22.
`Lessor Defendant Campus Advantage, Inc. (“Campus Advantage”) is a Delaware
`corporation headquartered in Austin, Texas. It is the nation’s fifteenth largest student housing
`manager.24 It specializes in property management for student housing communities and has over
`250 communities in 18 states.25 Campus Advantage is one of RealPage’s clients and uses its
`revenue management software.
`23.
`Lessor Defendant Cardinal Group Holdings, LLC (“Cardinal Group”) is a
`Delaware limited liability corporation headquartered in Denver, Colorado. It provides property
`management services to on-and-off campus student housing as well as conventional commercial
`
`
`20 Top 25 Owners & Managers 2021, Student Housing Business (November/December 2021)
`at 92, available at
`https://editions.mydigitalpublication.com/publication/?m=58489&i=733087&p=92&ver=html5
`(last visited June 14, 2023).
`21 Greystar Student Housing, Greystar, available at https://www.greystar.com/product-
`specialties/student-housing (last visited June 14, 2023).
`22 Top 25 Owners & Managers 2021, Student Housing Business (November/December 2021)
`at 92, available at
`https://editions.mydigitalpublication.com/publication/?m=58489&i=733087&p=92&ver=html5
`(last visited June 14, 2023).
`23 Timberline acquires new Columbia University Dorm for $84M, Real Estate Weekly (Nov.
`8, 2021), available at https://rew-online.com/timberline-acquires-new-columbia-university-dorm-
`for-84m/ (last visited June 14, 2023).
`24 Top 25 Owners & Managers 2021, Student Housing Business (November/December 2021)
`at 92, available at
`https://editions.mydigitalpublication.com/publication/?m=58489&i=733087&p=92&ver=html5
`(last visited June 14, 2023).
`25 Portfolio of Communities, Campus Advantage, available at
`https://campusadv.com/portfolio/ (last visited June 14, 2023).
`AMENDED CLASS ACTION COMPLAINT - 8
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`

`real estate and affordable housing units in 38 states, and employs over 2,000 people.26 Cardinal
`Group is one of RealPage’s clients and uses its revenue management software.
`24.
`Lessor Defendant CA Ventures Global Services, LLC (“CA Ventures”) is a
`Delaware limited liability corporation headquartered in Chicago, Illinois. It was founded in 2004
`as a niche investor and operator of student apartments, and has since delivered 29,995 beds in
`over 69 university markets. It employs over 570 people.27 CA Ventures is one of RealPage’s
`clients and uses its revenue management software.
`25.
`Lessor Defendant D.P. Preiss Company, Inc. (“Preiss Company”) is a North
`Carolina corporation headquartered in Raleigh, North Carolina. It is the ninth largest manager of
`student housing assets in the United States.28 In 2021, it had $1.75 billion in transaction
`volume.29 Preiss Company is one of RealPage’s clients and uses its revenue management
`software.
`26.
`Lessor Defendant University House Communities LLC (formerly Inland
`American Communities) is a wholly-owned subsidiary of InvenTrust Properties. University
`House Communities is headquartered in Dallas, Texas. In 2012, it was reported that University
`House Communities was beta testing LRO Student, a revenue management software later
`acquired by Defendant RealPage.30
`27.
`Lessor Defendant Carmel Partners LLC is a real estate investment manager that
`“specialize[s] in purchasing existing and developing multifamily assets in targeted U.S. markets
`
`
`26 Cardinal Group Companies, https://cardinalgroup.com/ (last visited June 14, 2023).
`27 CA Ventures, https://www.ca-ventures.com/real-estate/student (last visited June 14, 2023).
`28 Top 25 Owners & Managers 2021, Student Housing Business (November/December 2021)
`at 92, available at
`https://editions.mydigitalpublication.com/publication/?m=58489&i=733087&p=92&ver=html5
`(last visited June 14, 2023).
`29 SHB Interview: Preiss Co. Founder and CEO Donna Preiss Discusses Strategy and Goals
`Moving Forward (June 8, 2022), available at https://studenthousingbusiness.com/shb-interview-
`preiss-co-founder-and-ceo-donna-preiss-discusses-strategy-and-goals-moving-forward/ (last
`visited June 14, 2023).
`30 Jessica Fiur, The Rainmaker Group Launches Industry’s First Revenue Management
`Product Engineered Specifically for Student Housing, Multi-Housing News (Oct. 16, 2021),
`available at https://www.multihousingnews.com/the-rainmaker-group-launches-industrys-first-
`revenue-management-product-engineered-specifically-for-student-housing/ (last visited June 12,
`2023).
`AMENDED CLASS ACTION COMPLAINT - 9
`Case No. 3:23-md-3071
`Case 3:23-md-03071 Document 290 Filed 06/16/23 Page 13 of 107 PageID #: 1602
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`with relatively limited supply and high barriers to entry.”31 Carmel Partners is headquartered in
`San Francisco. In 2012, it was reported that “Carmel Properties” was beta testing LRO Student, a
`revenue management software later acquired by Defendant RealPage.32
`28.
`Lessor Defendant Timberline Real Estate Ventures LLC (“TREV”) is a privately
`held real estate operator and investment manager focused on the residential sector that has
`acquired more than $2.8 billion of total investments since its inception in 2012. TREV
`specializes in the development, acquisition, and operation of student housing, multifamily, and
`mixed-use retail/residential communities, and “utilize[es] its fully integrated property
`management team through its owned affiliate B.HOM Student Living with partner, BH
`Management Services.”33 TREV is headquartered is headquartered in Rye, NY.
`29.
`Lessor Defendant B.HOM Student Living LLC (“B.HOM”) is a student housing
`operator headquartered in Dallas, Texas. As noted above, B.HOM manages more than 30,000
`beds in properties at universities around the United States. Since approximately 2020, B.HOM
`has been a wholly owned affiliate of Defendant Timberline Real Estate Ventures.
`30.
`Lessor Defendants John Does are entities whose names are unknown at this time,
`but who used RealPage’s pricing software to price leases in the market for student housing real
`estate during the class period.
`III.
`JURISDICTION AND VENUE
`31.
`This Court has subject matter jurisdiction pursuant