"RealPage has undertaken this conduct with full and complete knowledge of its illegality. One of RealPage’s pricing software’s main architects, Jeffery Roper, i

"RealPage has undertaken this conduct with full and complete knowledge of its illegality. One of RealPage’s pricing software’s main architects, Jeffery Roper, is acutely familiar with the anticompetitive nature of coordinated algorithmic pricing within an industry. Before pioneering RealPage’s software, Roper was Alaska Airlines’ Director of Revenue Management when it and other airlines began using common software to share nonpublic planned routes and prices with each other, with the aim of heading off price wars. The Department of Justice’s Antitrust Division (“DOJ”) reached settlements or consent decrees for price fixing violations with eight airlines, including Alaska Airlines. Roper—who had his computer and documents seized by federal agents—relayed about that experience that, “We all got called up before the Department of Justice in the early 1980s because we were colluding.” He adds that at the time, “We had no idea” that conduct was unlawful. Having now brought analogous coordinated algorithmic pricing to multifamily residential real estate leasing after the DOJ’s airline settlements, however, Roper can no longer claim ignorance of the unlawful nature of this conduct" Case 3:22-cv-01611-WQH-MDD Document 1 Filed 10/18/22 PageID.17 Page 17 of 26