We need more lawsuits like this!
I. INTRODUCTION 1. From at least January 2016, through the present (the “Conspiracy Period”), Defendants engaged in a nationwide conspiracy to fix and inflate the price of multifamily rental housing across the country. Leveraging their control of the multifamily rental housing market from at least January 2016, Defendants conspired to limit supply and raise multifamily rental housing Case 3:23-md-03071 Document 728 Filed 02/05/24 Page 3 of 302 PageID #: 9023 4 prices, causing substantial damages to Plaintiffs and other members of the Class whose ability to obtain affordable housing depended on getting competitive prices for the units they rented. Several witness accounts, including 12 discussed herein, rental price and occupancy data, economic evidence, and public investigations,1 confirm the anticompetitive conduct taken pursuant to this agreement.
The Defendants:
RealPage, Inc., Thoma Bravo Fund XIII, L.P., Thoma Bravo Fund XIV, L.P., and Thoma Bravo
COMPANY; MID-AMERICA
COMMUNITIES, INC.; MID-AMERICA
APARTMENTS, L.P.; MISSION ROCK
RESIDENTIAL, LLC; MORGAN
PROPERTIES MANAGEMENT COMPANY,
LLC; PINNACLE PROPERTY
MANAGEMENT SERVICES, LLC;
PROMETHEUS REAL ESTATE GROUP,
INC.; THE RELATED COMPANIES, L.P.;
RELATED MANAGEMENT COMPANY L.P.;
ROSE ASSOCIATES, INC.; RPM LIVING,
LLC; SARES REGIS GROUP COMMERCIAL,
INC.; SECURITY PROPERTIES
RESIDENTIAL, LLC; SHERMAN
ASSOCIATES, INC.; SIMPSON PROPERTY
GROUP, LLC; THRIVE COMMUNITIES
MANAGEMENT, LLC; CROW HOLDINGS,
LP; TRAMMELL CROW RESIDENTIAL
COMPANY; UDR, INC.; WINDSOR
PROPERTY MANAGEMENT COMPANY;
WINNCOMPANIES LLC;
WINNRESIDENTIAL MANAGER CORP.;
AND ZRS MANAGEMENT, LLC.
Defendants.
Case 3:23-md-03071 Document 728 Filed 02/05/24 Page 2 of 302 PageID #: 9022
3
L.P. (collectively, “RealPage”); Apartment Management Consultants, LLC; Avenue5 Residential,
LLC; Bozzuto Management Company; First Communities Management, Inc.; FPI Management,
Inc.; Highmark Residential, LLC; Mission Rock Residential, LLC; Thrive Communities
Management, LLC; and ZRS Management, LLC (collectively the “Managing Defendants”);
Apartment Income REIT Corp., d/b/a Air Communities; Allied Orion Group, LLC; Bell Partners,
Inc.; BH Management Services, LLC; Brookfield Properties Multifamily LLC; Camden Property
Trust; CH Real Estate Services, LLC; CONAM Management Corporation; Cortland Management,
LLC; CWS Apartment Homes LLC; Dayrise Residential, LLC; ECI Group, Inc.; Equity
Residential; Essex Property Trust, Inc.; Greystar Management Services, LLC; Independence
Realty Trust, Inc.; Kairoi Management, LLC; Knightvest Residential; Lantower Luxury Living,
LLC; Lincoln Property Company; Mid-America Communities, Inc., and Mid-America
Apartments, L.P.; Morgan Properties Management Company, LLC; Pinnacle Property
Management Services, LLC; Prometheus Real Estate Group, Inc.; The Related Companies, L.P.;
Related Management Company L.P.; Rose Associates, Inc.; RPM Living, LLC; Sares Regis Group
Commercial, Inc.; Security Properties Residential, LLC; Sherman Associates, Inc.; Simpson
Property Group, LLC; UDR, Inc.; Windsor Property Management Company; WinnCompanies
LLC; and WinnResidential Manager Corp. (collectively, “Owner-Operators”); and CONTI Texas
Organization, Inc., d/b/a CONTI Capital; Crow Holdings, LP; and Trammell Crow Residential
Company (collectively “Owners”).
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