Key takeaways
- On July 6, 2026, the DOJ Antitrust Division filed a proposed settlement resolving its claims against Willow Bridge Property Company LLC.
- It follows proposed settlements in the same case with RealPage and three other large landlords — Cortland, Greystar, and LivCor.
- The proposed consent decree would bar anticompetitive pricing algorithms built on competitors' competitively sensitive data, bar sharing such data with competitors, and allow a court-appointed monitor in some circumstances.
- The settlement is proposed, subject to a public comment period under the Tunney Act, and must be entered by the court.
What happened
The Justice Department announced a proposed settlement with Willow Bridge as part of its ongoing enforcement action in the Middle District of North Carolina. The government's January 2025 complaint alleged that Willow Bridge and other landlord defendants set rents using each other's competitively sensitive information through pricing algorithms, and that they communicated with one another about pricing strategies, rents, and software parameters.
Under the proposed decree, Willow Bridge would refrain from using pricing algorithms that generate recommendations from competitors' competitively sensitive data or that include certain anticompetitive features; refrain from sharing competitively sensitive information with competitors; accept a court-appointed monitor if it uses a non-certified third-party pricing algorithm; refrain from attending RealPage-hosted meetings of competing landlords; and cooperate with the government's remaining claims.
As required by the Tunney Act, the proposed settlement and competitive impact statement are published in the Federal Register, with a 60-day comment window before the court decides whether entry is in the public interest.
What this means for landlords
The decree terms read like a compliance template. Regulators are drawing the line at three behaviors: pooling non-public competitor data, letting software translate that pooled data into aligned prices, and talking with competitors about the inputs.
Note what is not prohibited: using software, using your own historical data, or responding to publicly available market information. The problem is shared confidential inputs and coordinated outputs. Owners of any size who license revenue-management tools should be able to answer, on demand, where the recommendation data comes from.
Enforcement is also converging with state law. New Jersey's FAIR Act, signed two weeks after this filing, regulates the same conduct at the state level.
Action checklist
- Map your pricing stack: every tool, module, and consultant that touches rent recommendations.
- Request written vendor representations about data sources — specifically whether competitor non-public data is used.
- Prohibit, in writing, staff discussion of rents, concessions, or occupancy targets with competing operators.
- Keep contemporaneous notes showing independent rent decisions and the comparables relied on.
- Review trade-association and vendor-hosted meeting agendas before attending; skip sessions that involve competitor pricing detail.
- Preserve pricing records and vendor contracts; recordkeeping is the cheapest form of defense.
Sources
- U.S. Department of Justice, "Justice Department Reaches Proposed Settlement with Willow Bridge" (July 6, 2026) — https://www.justice.gov/opa/pr/justice-department-reaches-proposed-settlement-willow-bridge-one-americas-largest-landlords
This article is educational and is not legal advice. Antitrust exposure is fact-specific. Consult qualified counsel before changing pricing practices.