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Federal District Court Dismisses Manufactured Homes Price-Fixing Claims
12/17/2025On December 4, 2025, the U.S. District Court for the Northern District of Illinois dismissed a proposed price-fixing and information sharing class action against several manufactured housing companies and Datacomp Appraisal Systems, Inc., the nation’s largest manufactured and mobile home data vendor.In re Manufactured Home Lot Rents Antitrust Litig., No. 1:23-cv-06715 (N.D. Ill. Dec. 4, 2025). Judge Franklin U. Valderrama held the proffered class failed to plausibly allege a conspiracy to fix rent prices or properly define a relevant geographic market.
The court also dismissed plaintiffs’ state-law unjust enrichment claim, which rose and fell with the antitrust claims. Plaintiff-residents, who rent manufactured homes, alleged defendants violated Section 1 of the Sherman Act by providing confidential current and future rent information to a common vendor, who in turn provided pricing reports back to its customers. Plaintiffs alleged this data sharing scheme enabled defendants to collude on price and raise rents to supracompetitive levels. In addition, plaintiffs brought a standalone Section 1 information sharing claim.
Without direct evidence to support the existence of the conspiracy, plaintiffs were left to rely on circumstantial evidence. Plaintiffs alleged parallel rent increases by defendants nationwide, which outpaced both inflation and rent increases for single-family housing units. Plaintiffs bringing a Section 1 conspiracy claim based on circumstantial evidence must allege, in addition to defendants’ parallel conduct, “plus factors” that tend to show the parallel conduct resulted from coordination rather than independent decision making. Plaintiffs in this case advanced various “plus factors,” including the alleged information exchange, the purported concentration of the market, and defendants’ opportunities to conspire at trade association meetings and through pricing reports.
Plaintiffs also attempted to demonstrate that the manufactured housing defendants accepted an invitation to participate in the alleged anticompetitive conduct. To support this allegation, plaintiffs alleged that defendants provided competitively sensitive information to the same data vendor through telephone surveys and other means. Under plaintiffs’ theory, the vendor’s solicitation of the information was an invitation to collude, and defendants’ provision of the information constituted acceptance. The court concluded that, while this allegation supported an information sharing claim, it was insufficient to show an invitation to collude and acceptance.
The court similarly deemed plaintiffs’ alleged “plus factors” conclusory and inadequate. The court credited defendants’ reasoning that higher rental prices were plausibly caused by a decrease or stagnation in the manufactured housing supply accompanied by a contemporaneous increase in demand. Although the court noted its role is not to weigh two alternative plausible explanations for parallel pricing increases, it found defendants’ theory further demonstrated the improbability of plaintiffs’ conspiracy claims.
The court analyzed plaintiffs’ allegation of information sharing, which on its own can violate Section 1, under the rule of reason standard. Defendants argued plaintiffs failed to allege an unreasonable restraint of trade in part due to their failure to define a relevant market.
The court agreed, rejecting plaintiffs’ proposed nationwide market definition and holding that their argument that affected tenants would move across and throughout country was implausible. The court similarly held that plaintiffs failed to justify broad regional submarkets including large metropolitan statistical areas, pointing to constraints restricting the distance which tenants could move, such as commutes to work and school.
Plaintiffs’ state-law unjust enrichment claim was dismissed because it was tethered to their antitrust claims. The court also denied as moot a separate motion from one defendant raising personal jurisdiction and venue issues. The court granted leave to amend by early January 2026.
