A class-action lawsuit against Spotify led by rapper RBX, which accused the streaming giant of turning a blind eye to pervasive bot-farming on its platform, has been dismissed as of yesterday. In her June 22 ruling, California federal judge Josephine Stanton found that RBX had “failed to plausibly allege that the harm he has suffered outweighs any justification Spotify may have for maintaining its current policies regarding artificial streaming.”
Judge Stanton took issue with two core claims of the suit: that Spotify had been negligent in its duties towards protecting artists, and that it had violated California’s Unfair Competition Law. To the first point, she countered that RBX’s lawyers hadn’t sufficiently proven that the company had an obligation to address streaming fraud in the first place.
In her decision, the judge also noted that the suit devoted a disproportionate amount of attention to one artist in particular: Drake. “Plaintiff’s complaint focuses almost exclusively on the artificial streams of only one artist’s music,” she wrote, “so the extent to which plaintiff is injured by artificial streaming as a whole is unclear.”
Drake wasn’t actually named as a defendant or accused of wrongdoing; rather, he was cited as an example of an artist who has benefitted from the alleged fraud. The lawsuit claimed that a “non-trivial percentage” of Drake’s 37 billion total streams “appeared to be the work of a sprawling network of Bot Accounts.” Because Spotify’s payout model allocates royalties based on one’s share of the platform’s total streaming volume, the suit argued, fake streams of Drake’s music take money—an estimated “hundreds of millions of dollars”—out of the pockets of smaller musicians by inflating his slice of the pie.
A representative for RBX and his legal team has confirmed to Pitchfork that they plan to file an amended complaint “within the timeframe set by the Court”—20 days as of writing. Pitchfork has also reached out to representatives for Spotify for further comment.
Drake himself filed suit against Spotify and Universal Music Group in 2024, alleging that they engaged in illegal stream-boosting of Kendrick Lamar’s “Not Like Us.” He’s currently attempting to revive a separate lawsuit against UMG, seeking damages from the label for promoting the diss track on the grounds of defamation.
