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The agreement is between Real Estate One and named plaintiffs, with settlement class provisions and court approval requirements. It sets forth definitions, including the consolidated actions, parties, counsel, and operative effective-date conditions for final judgment, dismissal with prejudice, nationwide releases, and specified practice changes, without costs except as provided.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":36,"@type":70,"position":76},"https://docshare.wps.com/template/forms/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/real-estate-one-settlement-agreement/282869/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/real-estate-one-settlement-agreement/282869.png","ImageObject",442,249,{"name":88,"@type":89},"Arica Lee","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-23","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",8,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"What claims are at issue in the Settlement Agreement?","Question",{"text":109,"@type":110},"Plaintiffs allege Real Estate One and others participated in a conspiracy to raise, fix, maintain, or stabilize real estate commissions in violation of Section 1 of the Sherman Act.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"Who are the parties to the Settlement Agreement?",{"text":114,"@type":110},"The agreement is between defendant Real Estate One, Inc. and the plaintiffs Don Gibson, Lauren Criss, John Meiners, and Daniel Umpa, acting individually and on behalf of the Settlement Class.",{"name":116,"@type":107,"acceptedAnswer":117},"When does the Settlement become effective?",{"text":118,"@type":110},"The Settlement becomes effective when the Court enters a final judgment approving the settlement under Rule 23(e) and dismisses the actions against Real Estate One with prejudice, and the time for appeal has expired or any appeal is fully affirmed and no longer subject to further review.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},282869,1789584128,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":35,"category_name":36,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":136,"language":137,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":138,"faqs":139,"seo_title":140,"seo_description":61,"update_tm":126,"read_time":141},8796096645457,"https://ap-avatar.wpscdn.com/avatar/800003749518d68ffe3?x-image-process=image/resize,m_fixed,w_180,h_180&k=1779345340919836971","UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MISSOURI WESTERN DIVISION  \nDON GIBSON, LAUREN CRISS, JOHN MEINERS, and DANIEL UMPA, individually and on behalf of themselves and all others similarly situated,  \nPlaintiffs,  \nv.  \nTHE NATIONAL ASSOCIATION OF REALTORS,  \net al.,  \nDefendants.  \nCase No. 4:23-cv-00788-SRB  \n[Consolidated with 4:23-cv-00945-SRB]  \nSETTLEMENT AGREEMENT  \n1  \nCase 4:23-cv-00788-SRB Document 655-1 Filed 01/27/25 Page 10 of 81  \nThis Settlement Agreement (“Settlement Agreement”) is made and entered into this 6th day of December, 2024 (the “Execution Date”), by and between defendant Real Estate One, Inc.(“Real Estate One”) and Plaintiffs Don Gibson, Lauren Criss, John Meiners, and Daniel Umpa,(collectively “Plaintiffs”), who filed suit in the above captioned Actions (now consolidated) both individually and as a representative of the Settlement Class, as defined below.  \nWHEREAS, in the Actions Plaintiffs allege that Real Estate One and others participated ina conspiracy to raise, fix, maintain, or stabilize real estate commissions in violation of Section 1 of the Sherman Act;  \nWHEREAS, Real Estate One denies Plaintiffs’ allegations in the Actions and has asserted defenses to Plaintiffs’ claims;  \nWHEREAS, extensive arm’s-length settlement negotiations have taken place between Plaintiffs’Co-Lead Counsel and counsel for Real Estate One leading to this Settlement Agreement;  \nWHEREAS, the Actions will continue against the Non-Real Estate One Defendants unless Plaintiffs separately settle with any of the Non-Real Estate One Defendants;  \nWHEREAS, Plaintiffs have conducted an extensive investigation into the facts and the law regarding the claims asserted in the Actions, and have concluded that a settlement with Real Estate One according to the terms set forth below is fair, reasonable, and adequate and in the best interest of Plaintiffs and the Settlement Class;  \nWHEREAS, Real Estate One believes that it is not liable for the claims asserted and that it has meritorious defenses to Plaintiffs’ claims and meritorious pre-trial and post-trial motions, but nevertheless has decided to enter into this Settlement Agreement to avoid further expense, inconvenience, and the distraction of burdensome and protracted litigation, to obtain the nationwide releases, orders, and judgment contemplated by this Settlement Agreement, and to put  \n2  \nCase 4:23-cv-00788-SRB Document 655-1 Filed 01/27/25 Page 11 of 81  \nto rest with finality all claims that Plaintiffs and Settlement Class Members have or could have asserted against the Released Parties, as defined below; and  \nWHEREAS, Real Estate One, in addition to the settlement payments set forth below, has agreed to cooperate with Plaintiffs and to implement certain practice changes, each as set forth in this Settlement Agreement.  \nNOW, THEREFORE, in consideration of the agreements and releases set forth herein and other good and valuable consideration, and intending to be legally bound, it is agreed by and between Real Estate One and the Plaintiffs that the Actions be settled, compromised, and dismissed with prejudice as to Real Estate One only, without costs to Plaintiffs, the Settlement Class or Real Estate One except as provided for herein, subject to the approval of the Court, on the following terms and conditions:  \nA. Definitions  \nThe following terms, as used in this Settlement Agreement, have the following meanings:  \n1. “Actions” means Gibson v. NAR, (W.D. Mo. Case No. 4:23-cv-00788-SRB) and Umpa v. NAR,(W.D. Mo. Case No. 4:23-cv-945-SRB) .  \n2. “Corporate Defendants” means any defendant aside from the National Association of Realtors that have been named in the Actions, Burnett v. NAR, (W.D. Mo. Case No. 19-cv- 00332-SRB), or Moehrl v. NAR,(N.D. Ill. Case No. 1:19-cv-01610) .  \n3. “Co-Lead Counsel” means the following law firms:  \nKETCHMARK AND MCCREIGHT P.C.  \n11161 Overbrook Road, Suite 210  \nLeawood, KS 66211  \nBOULWARE LAW LLC  \n1600 Genessee, Suite 956A ","cbCaihJEps532UO7","https://ap.wps.com/l/cbCaihJEps532UO7","pdf",329525,37,"English","# A. Definitions\n## Actions\n## Corporate Defendants\n## Co-Lead Counsel\n## Court\n## Defendants\n## Effective\n## Effective Date","[{\"question\":\"What claims are at issue in the Settlement Agreement?\",\"answer\":\"Plaintiffs allege Real Estate One and others participated in a conspiracy to raise, fix, maintain, or stabilize real estate commissions in violation of Section 1 of the Sherman Act.\"},{\"question\":\"Who are the parties to the Settlement Agreement?\",\"answer\":\"The agreement is between defendant Real Estate One, Inc. and the plaintiffs Don Gibson, Lauren Criss, John Meiners, and Daniel Umpa, acting individually and on behalf of the Settlement Class.\"},{\"question\":\"When does the Settlement become effective?\",\"answer\":\"The Settlement becomes effective when the Court enters a final judgment approving the settlement under Rule 23(e) and dismisses the actions against Real Estate One with prejudice, and the time for appeal has expired or any appeal is fully affirmed and no longer subject to further review.\"}]","Real Estate One Settlement Agreement | PDF",13]