The settlement formalizes modifications RealPage had already implemented during litigation that began in 2024. The specific terms of the compliance framework and monitoring arrangements have not yet been detailed in public filings. The Tunney Act review process will determine whether additional modifications are required before final approval.
This settlement marks the DOJ's first enforcement action of this type and signals heightened scrutiny of algorithmic pricing tools across industries. Attorneys should audit how their clients' software uses competitor data and pricing information, particularly in sectors like real estate, hospitality, and retail. California's AB 325, effective January 2026, already prohibits algorithms that rely on competitor data. Expect similar state-level restrictions and continued federal enforcement actions targeting both software vendors and their customers. Companies should review data governance practices now and consider whether existing information-sharing arrangements with competitors create antitrust exposure.