IN RE: Realpage, Inc., Rental Software Antitrust Litigation (No. II)

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
IN RE: REALPAGE, INC., RENTAL
SOFTWARE ANTITRUST
LITIGATION (NO. II)
NO. 3:23-md-03071
THIS DOCUMENT RELATES TO:
ALL CASES
STIPULATION AND ORDER
Plaintiffs and Defendants, RealPage, Inc., Morgan Properties Management Company, LLC,
UDR, Inc., Independence Realty Trust, Inc., and Thoma Bravo L.P., Thoma Bravo Fund XIII, L.P.,
and Thoma Bravo Fund XIV, L.P., (“Parties”), by and through their counsel of record, hereby
stipulate and request to approve as follows:
1. 	The Parties’ deadline to file motions for class certification and Daubert motions
is October 2, 2026. (Doc. No. 1453).
2. 	The briefing and supporting exhibits related to the class certification and Daubert
motions will involve a significant volume of materials that the Parties and various nonparties,
including Defendants who have settled this action, have designated Confidential or Highly
Confidential under the Protective Order entered in this case. (Doc. No. 828).
3. 	To conserve the resources of the Court and the Parties and to reduce the number of
motions to seal filed with the Court, the Parties have filed provisional motions to seal for these
materials in the first instance.
4. 	In order to provide additional time for all interested Parties to meet and confer and
narrow any disputes, the Parties respectfully request that Defendants be permitted to file one
omnibus submission in support of sealing materials 21 days from now (by October 23, 2026) after
meeting and conferring with Plaintiffs, and Plaintiffs be permitted to file one omnibus submission
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with the grounds for any opposition to sealing 14 days thereafter (November 6, 2026).
5. 	The Parties have agreed to, and respectfully submit for approval by the Court, the
following sealing procedure for the Parties’ forthcoming class certification and Daubert motions:
a. 	The Parties will provisionally file under seal any materials submitted in
connection with class certification and Daubert motions due on October 2,
2026 and relying on documents or data designated Confidential or Highly
Confidential under the Protective Order, Doc. No. 828.
b. 	The Parties shall meet and confer with each other and any non-parties or
settled Defendants whose materials have been provisionally filed under
seal, and the Defendants will file an omnibus motion in support of sealing
any documents that Defendants believe should remain under seal by October
23, 2026 (21 days after filing of the Parties’ class certification and Daubert
motions).
c. 	Plaintiffs will file any response to Defendants’ motion by November 6, 2026
(14 days after any filing of Defendants omnibus motion in support of
sealing).
The Joint Motion (Doc. No. 1571) is APPROVED.
IT IS SO ORDERED.
WAVERLY D. CRENSHAW, JR.
UNITED STATES DISTRICT JUDGE
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