The Notice has been posted for the benefit of potential members of the Settlement Class. If you are uncertain about whether you are a member of the Settlement Class, you may contact the Settlement Administrator at 888-995-0207.

The Notice has been posted because members of the Settlement Class have a right to know about the proposed settlements of a class action lawsuit in which they are class members, and about all of their options, before the Court decides whether to approve the Settlements. If the Court approves the Settlements, and after objections or appeals relating to the Settlements are resolved, the benefits provided by the Settlements will be available to members of the Class.

The Notice explains the lawsuits, the Settlements, your legal rights, what benefits are available, who is eligible for them, and how to get them. A full copy of the Settlement Agreements may be viewed on the Important Documents page. The Notice contains only a summary of the Settlements.

The Court in charge of the Settlements with William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA is the United States District Court for the Western District of Missouri. There are two cases at issue. They are Gibson et al. v. National Association of Realtors et al., (W.D. Mo. Case No. 23-CV-788-SRB) , which is consolidated with Umpa v. National Association of Realtors et al., (W.D. Mo. Case No. 4:23-cv-00945) (“Gibson”) and Keel v. National Association of Realtors et al., (W.D. Mo. Case No. 25-cv-00759) (“Keel II”). The people who filed this lawsuit are called the Plaintiffs. The people being sued are called the Defendants. Defendants in the Gibson action include large real estate brokerage firms and families of firms, including:

Many Defendants in Gibson have already settled, and more Defendants may settle in the future. Of these Gibson Defendants, the Notice concerns only William Raveis, Howard Hanna, EXIT, Windermere, Lyon. The Keel II case includes Charles Rutenberg, My Home, Tierra Antigua, and West USA. All four of those Defendants have settled. Notice of additional settlements is also available on the Important Documents page for each prospective settlement. You may view each group of Settlements on the All Settlements page.

These Settlements may also release claims against William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA raised in other lawsuits involving alleged anticompetitive conduct in connection with commissions charged by brokers and agents in residential real estate transactions. Those other lawsuits are discussed further below in response to FAQ 22.

The lawsuits claim that Defendants, including William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA, created and/or implemented rules that require home sellers to pay commissions to the broker or agent representing the buyer and that caused home sellers to pay total commissions at inflated rates. They also allege that Defendants enforced these rules through anticompetitive and unlawful practices.

The lawsuits claim that these rules are anticompetitive and unfair, and that they violate antitrust laws. You can read Plaintiffs’ complaints on the Important Documents page. Specifically, the lawsuits allege violations of the Sherman Act (a federal antitrust statute found at 15 U.S.C. § 1 et seq.) among other things. The Sherman Act claims apply to home sales that occurred anywhere in the United States during the Eligible Date Range.

Although the Court has authorized notice to be given of the proposed Settlements, the Notice does not express the opinion of the Court on the merits of the claims or defenses asserted by either side of the lawsuit.

William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA dispute Plaintiffs’ allegations and deny all liability to Plaintiffs and the Class. On October 31, 2023, a jury found in favor of Plaintiffs against different defendants in an action involving similar claims and allegations: Burnett et al. v. National Association of Realtors, et al., Case No. 19-CV-00332-SRB (Western District of Missouri) (“Burnett”).

In a class action, one or more people called Class Representatives sue on behalf of other people who have similar claims. The people together are a “Class” or “Class Members.” The consumers who sued Defendants—and all the Class Members like them—are called Plaintiffs. The companies they sued are called the Defendants. One court resolves the issues for everyone in the Class – except for those who choose to exclude themselves from the Class.

Here, the Court decided that this lawsuit can be a class action for settlement purposes because it preliminarily meets the requirements of Federal Rule of Civil Procedure 23, which governs class actions in federal courts. Specifically, the Court found that: (1) there are numerous people who fit the class definition; (2) there are legal questions and facts that are common to each of them; (3) the Plaintiffs’ claims are typical of the claims of the rest of the Class; (4) Plaintiffs, and the lawyers representing the Class, will fairly and adequately represent the Class Members’ interests; (5) the common legal questions and facts are more important than questions that affect only individuals; and (6) this class action will be more efficient than having individual lawsuits.

Although Plaintiffs prevailed at trial against other defendants in the related Burnett action, involving similar claims and allegations, the Court has not ruled in favor of the Plaintiffs or Defendants in the Gibson or Keel II actions. Counsel for the Settlement Class investigated the facts and applicable law regarding Plaintiffs’ claims and Defendants’ defenses, potential issues at trial and on appeal, and the Defendants’ ability to pay. The parties engaged in arms-length negotiations to reach the Settlements. Plaintiffs and Counsel for the Settlement Class believe that the proposed Settlements are fair, reasonable, and adequate, and in the best interest of the Class.

Both sides agree that by settling, William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA are not admitting any liability or that they did anything wrong. Both sides want to avoid the uncertainties and expense of further litigation.

To be eligible to receive the benefits of the Settlements, you must have: (1) sold a home during the Eligible Date Range; (2) listed the home that was sold on a multiple listing service (“MLS”) anywhere in the United States; and (3) paid a commission to any real estate brokerage in connection with the sale of the home. The Eligible Date Ranges can be found below for William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA.

You did not need to have sold a home using a William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, or West USA agent to make a claim.

You are a part of the Settlement Class if you: (1) sold a home during the Eligible Date Range; (2) listed the home that was sold on a multiple listing service anywhere in the United States; and (3) paid a commission to a real estate brokerage in connection with the sale of the home. More information about the Eligible Date Range for each Settlement can be found in each Settlement Agreement on the Important Documents page.

If you are uncertain as to whether you are a member of the Settlement Class, you may contact the Settlement Administrator at 888-995-0207 to find out.

If you are a member of the Settlement Class, you are eligible to receive a benefit under the Settlements.

The Settling Defendants named here have agreed to pay $42,787,500 into a settlement fund as follows: William Raveis ($4.1 million), Howard Hanna ($32 million), EXIT ($1.5 million), Windermere, Lyon ($2.1 million), Charles Rutenberg ($750,000), Tierra Antigua ($400,000), West USA Realty ($950,000), and My Home ($987,500).

The settlement fund will be distributed to qualifying Settlement Class Members who submit an approved claim form, after any awarded attorneys’ fees, expenses, settlement administration costs, and service awards have been deducted. William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA have also agreed to implement Practice Changes and provide Cooperation. You can learn more about the Practices Changes and Cooperation in the Settlement Agreements, which are available on the Important Documents page.

Note: If you have already submitted a claim form for a prior settlement with other Defendants, you do not need to submit another claim form. But if you did not previously file a claim form, then you will be eligible to make a claim for the settlements with only William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, but not for prior settlements.

To receive a benefit, a Settlement Class Member must submit a claim form with information pertaining to and/or evidence of your home sale and commissions paid to the Notice and Claims Administrator. The Notice and Claims Administrator will be responsible for reviewing all claim forms and evidence of purchase to determine whether a claim is an approved claim. The Notice and Claims Administrator will reject any claim that is not: (a) submitted timely and in accordance with the directions on the claim form, the provisions of these Settlement Agreements, and the Preliminary Approval Order; (b) fully and truthfully completed by a Settlement Class Member or their representative with all of the information requested in the claim form; and (c) signed by the Settlement Class Member. Claims that cannot be confirmed by the Settlement Administrator may be subject to challenge, nonpayment, or a reduced share of the available funds.

You can submit a claim form online or by printing the claim form from the Important Documents page and returning it to the Settlement Administrator via mail or email on or before December 30, 2025.

Gibson et al. v. The National Association of Realtors et al.
c/o JND Legal Administration
PO Box 91479
Seattle, WA 98111
Email: info@RealEstateCommissionLitigation.com

The Court will hold a final Fairness Hearing on February 5, 2026 at 1:30 PM and at 2:30 PM for Gibson and Keel II, respectively, in the United States District Court for the Western District of Missouri, 400 E. 9th St., Courtroom 7B, Kansas City, Missouri 64106, to decide whether to finally approve the Settlements. If the Settlements are approved, there may be appeals. Payments to members of the Settlement Class will be made only if the Settlements are approved and after any appeals are resolved. This may take some time, so please be patient.

Upon the Court’s approval of the proposed Settlements, all members of the Settlement Class who do not exclude themselves (as well as their representatives) will release William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA (and their affiliates, subsidiaries, franchisees, employees, and certain others as specified in the Settlement Agreements).

All members of the Settlement Class who do not exclude themselves will release claims whether known or unknown that they ever had, now have, or hereafter may have and that have accrued as of the date of preliminary approval of the Settlements arising from or related to the Released Claims. “Released Claims” means any and all manner of claims regardless of the cause of action arising from or relating to conduct that was alleged or could have been alleged in the Actions based on any or all of the same factual predicates for the claims alleged in the Actions, including but not limited to commissions negotiated, offered, obtained, or paid to brokerages in connection with the sale of any residential home.

The release does not extend to any individual claims that a Class Member may have against his or her own broker or agent based on a breach of contract, breach of fiduciary duty, malpractice, negligence or other tort claim, other than a claim that a Class Member paid an excessive commission or home price due to the claims at issue.

This release may affect your rights, and may carry obligations, in the future. To view terms of the release, review the Settlement Agreements, which are available on the Important Documents page.

To ask to be excluded, you must execute and send a Request for Exclusion to the Settlement Administrator submitted or postmarked on or before December 30, 2025. A Request for Exclusion must include the potential Settlement Class Member’s present name and address, the address of the home(s) sold and approximate date(s) of sale of the home(s), a clear and unequivocal statement that the potential Settlement Class Member wishes to be excluded from the Settlement Class as to William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, and the signature of the putative Settlement Class Member or, in the case of a potential Settlement Class Member who is deceased or incapacitated only, the signature of the legally authorized representative of the putative Settlement Class Member.

Note: if you did not exclude yourself from previous settlements, you may still exclude yourself from some or all of these eight Settlements.

If the request is not submitted or postmarked on or before December 30, 2025, your exclusion will be invalid, and you will be bound by the terms of the Settlements approved by the Court, including without limitation, the judgment ultimately rendered in the case, and you will be barred from bringing any claims against William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, or their affiliates as outlined in FAQ 11 which arise out of or relate in any way to the claims in the case as specified in the release referenced in FAQ 11.

You must submit your Exclusion Request to:

Gibson et al. v. The National Association of Realtors et al.
Keel II v. The National Association of Realtors et al.
c/o JND Legal Administration – Exclusion Dpt.
PO Box 91486
Seattle, WA 98111
Email: info@RealEstateCommissionLitigation.com
 

No. Unless you exclude yourself, you give up any right to sue William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, and their Released Parties for the claims that the Settlements resolve. If you have a pending lawsuit against William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, their Released Parties, or certain affiliated entities such as MLSs or small brokers, speak to your lawyer in that case immediately. You may have to exclude yourself from this Class to continue your own lawsuit. Remember, the exclusion deadline is December 30, 2025.

No. If you exclude yourself as to the Settlements with William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, do not send in a claim form to ask for any money. If you exclude yourself only as to some of these Defendants, you may still ask for money from the Settlements with other Defendants. If you exclude yourself as to William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and/or West USA, you may sue, continue to sue, or be a part of a different lawsuit against these Defendants.

The Court decided that the law firms Ketchmark and McCreight P.C.; Williams Dirks Dameron LLC; Boulware Law LLC; Hagens Berman Sobol Shapiro LLP; Cohen Milstein Sellers & Toll PLLC; and Susman Godfrey LLP, are qualified to represent you and all other Settlement Class Members. These lawyers are called “Class Counsel.” You will not be charged for these lawyers. They are experienced in handling similar cases against other entities. More information about the law firms, their practices, and their lawyers’ experience is available at: www.KansasCityLawOffice.com, www.WilliamsDirks.com, www.Boulware-Law.com, www.HBSSLaw.com, www.CohenMilstein.com, and www.SusmanGodfrey.com.

Class Counsel represent the interests of the Settlement Class. You may hire your own attorney to advise you, but if you hire your own attorney, you will be responsible for paying that attorney’s fees.

Class Counsel will ask the Court for attorneys’ fees, in an amount not to exceed one-third (33.3%) of the settlement fund, plus out-of-pocket expenses incurred. The Court may award less. Class Counsel may also seek compensation for each current and/or former class representative in Gibson and Keel II.

The Class Representatives will make their request for attorneys’ fees, costs, and service awards on or before December 1, 2025 and that request will be published on the Important Documents page.

William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA will pay the fees and expenses that the Court awards from the settlement fund. You are not responsible for any fees or expenses that the Court awards.

If you are a Class Member, you can object to these Settlements if you do not like any part of them, including the forthcoming motion for attorneys’ fees, costs and service awards. You can give reasons why you think the Court should not approve them. The Court will consider your view. To object, you must file or send a written objection to the Court, as instructed by the Court, by December 30, 2025, or you will waive your right to object (whether in opposition to the motion for Final Approval, motion for attorneys’ fees, costs and service awards, on appeal, or otherwise) to the Settlements. Be sure to include the case name and number (Gibson et al. v. The National Association of Realtors et al., Case No. 23-cv-788-SRB and/or Keel II et al. v. National Association of Realtors et al., Case No. 25-cv-00759), as well as the following information:  (a) your full name, address, telephone number and email address, if any; (b) the address of the home(s) sold, the date of the sale, the listing broker(s), and the buyer’s broker(s); (c) a specific statement of all grounds for your objection and, if applicable, any legal support for the objection; (d) a statement whether the objection applies only to you, to a specific subset of one or more of the Settlement Classes, or to the entirety of all of the Settlement Classes; (e) a statement whether the objection applies to all of the Settlement Classes addressed in this order or only those with certain of the Settling Defendants; (f) the name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection; (g) a list of all class action settlements to which you have objected in the past five (5) years, if any; (h) copies of any papers, briefs, or other documents upon which the objection is based; and (i) your signature.

You must file any objection with the Clerk of the Court at the address below by December 30, 2025:

United States District Court for the Western District of Missouri
400 E. 9th St., Room 7462, Kansas City, Missouri 64106
Gibson et al. v. The National Association of Realtors et al., Case No. 23-cv-788-SRB
and/or Keel II et al.  v. National Association of Realtors et al., Case No. 25-cv-00759.

You must also send your objection by first class mail, postmarked on or before December 30, 2025, to Class Counsel and Defendants’ Counsel at the following addresses:

Any member of the Settlement Class who does not file and serve an objection in the time and manner described above will not be permitted to raise that objection later. If you send an objection, you may need to personally appear at the Fairness Hearing on February 5, 2026 at 1:30 PM and at 2:30 PM for Gibson and Keel II, respectively, or your objection may be waived. Please check the settlement website and/or Court docket for the Court’s instruction.

Objecting is simply telling the Court that you don’t like something about the Settlements. You can object to a Settlement only if you stay in it. Excluding yourself is telling the Court that you do not want to be part of a Settlement. If you exclude yourself, you have no basis to object because the Settlement no longer affects you.

There will be a final Fairness Hearing to consider approval of the proposed Settlements on February 5, 2026  at 1:30 PM and at 2:30 PM for Gibson and Keel II, respectively, at the United States District Court for the Western District of Missouri, 400 E. 9th St., Courtroom 7B, Kansas City, Missouri 64106. The hearing may be postponed to a later date without further individual notice. Any such postponements will be posted on the Court docket and/or the Key Dates page. The purpose of the hearing is to determine the fairness, reasonableness, and adequacy of the terms of the Settlements, whether the Settlement Class is adequately represented by the Plaintiffs and Class Counsel, and whether an order and final judgment should be entered approving the proposed Settlements. The Court will also consider Class Counsel’s application for an award of attorneys’ fees and expenses, and any class representative service awards.

If you do not object to the Settlements, you will be represented by Class Counsel at the Fairness Hearing unless you choose to enter an appearance in person or through your own counsel. The appearance of your own attorney is not necessary to participate in the Fairness Hearing.  If you send an objection, you may need to personally appear at the Fairness Hearing on February 5, 2026, or your objection may be waived. Please check the settlement website and/or Court docket for the Court’s instruction.

If you do not object, you do not need to come to the hearing. Class Counsel will represent the Settlement Class at the Fairness Hearing, but you are welcome to come at your own expense. You may also pay your own lawyer to attend if you wish. If you send an objection, you may need to personally appear at the Fairness Hearing on February 5, 2026, or your objection may be waived. Please check the Important Documents page and/or Court docket for the Court’s instruction.

You may ask the Court for permission to speak at the Fairness Hearing. To do so, you must send a letter saying “Notice of Intention to Appear in Gibson et al.  v. National Association of Realtors et al., Case No. 23-CV-788-SRB” and/or “Notice of Intention to Appear in Keel II et al.  v. National Association of Realtors et al., Case No. 25-cv-00759.” Be sure to include your name, address, telephone number and your signature. Your Notice of Intention to Appear must be submitted or postmarked no later than December 30, 2025, and be sent to the Clerk of the Court, Class Counsel and Counsel for William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA at the addresses in FAQ 17. You cannot speak at the hearing if you exclude yourself.

In addition to Gibson and Keel II, there are numerous other class actions involving similar claims, including: Keel, et al. v. Washington Fine Properties LLC, et al., Case No. 4:25-cv-00055-FJG (W.D. Missouri); Burnett et al., v. National Ass'n of Realtors et al., Case No. 19-CV-00332-SRB (W.D. Missouri); Moehrl et al., v. National Ass'n of Realtors et al., Case No. 1:19-cv-01610 (N.D. Illinois); Batton v. NAR, Case No. 1:21-cv-00430 (N.D. Ill.); Batton v. Compass, Case No. 1:23-cv-15618 (N.D. Ill.); Burton v. NAR, Case No. 7:23-cv-05666-JD (D.S.C.); QJ Team, LLC and Five Points Holdings, LLC v. TAR, Case No. 4:23-cv-01013 (E.D. Tx.); March v. REBNY, Case No. 1:23-cv-09995 (S.D.N.Y.); 1925 Hooper LLC v. NAR, Case No. 1:23-cv-05392-SEG (N.D. Ga.); Kay v. West Penn Multi-List, Inc., Case No. 2:23-cv-2061 (W.D. Pa.); Grace v. NAR, Case No. 3:23-cv-06352 (N.D. Cal.); Masiello v. Arizona Association of Realtors, Case No. 2:24-cv-00045 (D. Ariz.); Tuccori v. At World Properties, LLC, Case No. 2:24-cv-00150 (N.D. Ill.); Whaley v. Arizona Association of Realtors, Case No. 2:24-cv-00105 (D. Nev.); Fierro v. National Association of Realtors, Case No. 2:24-cv-00449 (C.D. Cal.); Friedman v. REBNY et al., Case No. 1:23-cv-00405 (S.D.N.Y.); Willsim Latham v. MetroList, Case No. 2:24-cv-00244 (E.D. Cal.); Jensen v. National Ass’n of Realtors et al., Case No. 2:24-cv-00109 (D. Utah); Peiffer v. Latter & Blum Holding, LLC, et al., Case No. 2:24-cv-00557 (E.D. La.); Wang v. National Ass'n of Realtors et al., Case No. 1:24-cv-02371 (S.D.N.Y.); Jutla v. Redfin Corporation, 2:24-cv-00464 (W.D. Wash.); Burton v. Bluefield Realty, Case No. 7:24−cv−01800-JDA (D.S.C.); 1925 Hooper LLC v. Watson Realty Corp., Case No. 3:24-cv-00374 (M.D. Fla.); Wallach v. Silvercreek Realty Group LLC, Case No. 1:24-cv-3356 (N.D. Ill.); Lutz v. HomeServices of America, Inc., et al., 4:24-cv-10040-KMM (S.D. Fla.); Davis v. Hanna Holdings, Inc., 2:24-cv-02374 (E.D. Pa.); Hartz v. Real Estate One, Inc., Case No.   1:24-cv-03160 (N.D. Ill.); Maslanka, et. al. v. Baird & Warner, Inc., Case No. 1:24-cv-02399 (N.D. Ill.); and Wutsch v. William Raveis Real Estate, Inc., X08-FST-CV24-6067981-S (Conn. Super. Ct.), among others.

The Settlements may release claims against William Raveis, Howard Hanna, EXIT, Windermere, Lyon, Charles Rutenberg, My Home, Tierra Antigua, and West USA, and other Released Parties, asserted on behalf of members of the putative classes in those cases. But the Settlements may not release claims against other Defendants in those cases. If you are a member of a putative class in any other cases involving similar claims, you may have additional rights to participate in or exclude yourself from ongoing litigation or settlements in those cases.

The Notice is only a summary. For a more detailed statement of the matters involved in the lawsuit or the Settlements, you may refer to the papers filed in this case during regular business hours at the office of the Clerk of Court, United States District Court for the Western District of Missouri, 400 E. 9th St, Kansas City, Missouri 64106: Gibson et al. v. The National Association of Realtors et al., Case No. 23-CV-788-SRB; and Keel II et al. v. National Association of Realtors et al., Case No. 25-cv-00759. The full Settlement Agreements and certain pleadings filed in the cases are also available on the Important Documents page, or can be requested from Class Counsel, identified in the answers to FAQ 15 and FAQ 17, or from the Settlement Administrator, with the contact information provided in FAQ 9.