A US federal judge has permanently dismissed rapper RBX’s lawsuit accusing Spotify of letting bots inflate streams of Drake’s music at the expense of other artists’ royalties.
On October 23, Judge Josephine Staton, of the US District Court for the Central District of California, granted Spotify’s request to throw out the case.
It is the second time Staton has dismissed the case – and this time, she barred RBX from bringing the same claims again.
The 16-page ruling can be read in full here.
RBX, whose legal name is Eric Dwayne Collins, first sued Spotify in November 2025, seeking to represent a class of US rights holders whose music is on the platform. He brought claims for negligence and for violation of California’s Unfair Competition Law (UCL).
The case rested on how Spotify pays royalties: subscription and advertising revenue in each market is pooled monthly, then split according to each track’s share of streams in that market.
Under that model, Collins argued, every fake stream credited to one catalog reduces what every other rights holder is paid.
Drake, whom the complaint called “the most streamed artist of all time,” was its central example.
Drake was not named as a defendant in the case.
The amended complaint claimed that, over what it described as a 48-month sampling period through 2025, “a substantial, non-trivial percentage of Drake’s approximately 37,000,000,000 streams on Spotify during that timeframe were inauthentic and appeared to be the work of a sprawling network of Bot Accounts.”
It estimated that the alleged fraud had “diverted at least $600 million in royalties away from music rights holders.”
Collins sought compensatory and punitive damages, plus an order requiring Spotify to hand over revenues it earned through the alleged conduct.
Beyond the USD $600 million estimate, the amended complaint did not put a figure on the damages Collins sought, leaving the amount to be proven at trial.
He also asked the court to supervise Spotify in identifying and removing fake streams, with the help of an independent monitor, and to order the company to tighten its sign-up process with checks such as CAPTCHAs and a valid mobile number or credit card.
At the heart of the amended complaint was the allegation that Spotify enforces its anti-fraud rules selectively.
“Spotify rigorously polices the low end of its streaming platform, where enforcement costs Spotify nothing and in fact, benefits its bottom line by imposing minimum-stream and unique listener thresholds that strip royalties from emerging and independent artists,” Collins’s filing alleged.
“Yet, at the same time, Spotify declines to apply that same scrutiny to artificial streaming that inflates the catalogs of its highest-volume, ‘A-list,’ most lucrative artists such as Drake, the very accounts whose streams drive Spotify’s reported monthly active users, engagement metrics, and advertising revenue,” it continued.
Since April 2024, Spotify has required a track to reach at least 1,000 streams over the previous 12 months before it qualifies for recorded music royalties, alongside an undisclosed minimum number of unique listeners.
The minimum-stream threshold was among the royalty changes first reported by MBW in October 2023.
In her ruling, Staton found that Collins had not shown Spotify owed him a legal duty to protect against third-party bots.
“Although Plaintiff may have less power in the music industry as compared to Spotify, that does not mean his relationship with Spotify is characterized by any protection Spotify gives to Plaintiff,” Staton wrote. “Rather, the allegations still show that the parties’ relationship is primarily a mutually beneficial economic one, albeit one with a power imbalance typical of an economic relationship between a corporate entity and an individual.”
The judge also pointed to how the complaint described Collins: as a “world-renowned performer” holding royalty rights in “notable and commercially successful songs and albums.”
“Thus, as alleged, Plaintiff is not a small or vulnerable artist,” Staton wrote.
The amended complaint had argued that an artist’s share of Spotify streams affects far more than royalties, including tour slots, brand partnerships, and placements in TV and film. Collins contended that this meant Spotify was safeguarding artists’ careers, not just their income.
Staton said that missed the mark, writing: “Spotify’s purpose is not to protect Plaintiff’s ‘career and status in the music community.’ That streaming activity on Spotify’s platform may impact Plaintiff’s career and status does not transform Spotify’s role into one of a protector.”
“Spotify’s purpose is not to protect Plaintiff’s ‘career and status in the music community.’ That streaming activity on Spotify’s platform may impact Plaintiff’s career and status does not transform Spotify’s role into one of a protector.”
Josephine Staton, US District Judge
The judge was no more persuaded by the amended complaint’s alternative argument that Spotify had voluntarily taken on a duty to protect rights holders through its own anti-fraud policies. That theory requires physical harm, she noted, and Collins could not allege any.
On the claim that Spotify had misled rights holders, Staton found that its stated aim of ensuring “a level playing field” was not a factual assertion that could be proven false. The statement “is merely one reflecting its aspirations and goals,” she wrote.
Spotify’s statement that it conducts “daily cleaning to ensure artificial streams are removed from public numbers in the Spotify app” was more specific, the judge said, but Collins had not shown it was false.
“Plaintiff does not allege any facts showing that Spotify does not conduct daily cleaning of artificial streams,” Staton wrote. “The alleged facts suggest only that artificial streaming still exists on Spotify.”
On selective enforcement, Staton wrote that “the fact that these thresholds exist and may disproportionately impact smaller artists is not hidden from consumers in any way.”
Staton added that the complaint did “not identify a single protocol that exists but has not been impartially enforced.” What Collins described, she wrote, was “not a theory of selective enforcement, but of disparate impact.”
Citing the complaint’s own description of how bot vendors operate, Staton wrote: “Plaintiff does not allege any facts suggesting that halting artificial streaming by these bots, which are designed by ‘specialized’ vendors to ‘avoid detection,’ would be easy for Spotify.”
Staton pointed out that the UCL exists to protect consumers and competitors. Collins, she found, had alleged no harm to either – only losses suffered as a rights holder whose music is on the platform.
The complaint faulted Spotify for not requiring a credit card to open a free account, a practice the judge said “would likely help, not hurt, consumers who wish to create free accounts and listen to music on Spotify.”
Staton ruled that giving Collins another chance to rewrite his complaint “would be futile.”
The ruling did not decide whether the complaint’s account of Drake’s streams was accurate.
Instead, Staton found that, even accepting its factual allegations as true, the complaint did not set out a valid legal claim against Spotify.
Mark Pifko, one of the lead attorneys for Collins, told Rolling Stone: “We are reviewing the order, but an appeal is likely.”
The order gave Spotify five days to submit a proposed judgment. Any appeal would go to the US Court of Appeals for the Ninth Circuit.
MBW has contacted Spotify for comment.
Responding to the original lawsuit in November 2025, a Spotify spokesperson said the company “in no way benefits from the industry-wide challenge of artificial streaming.”
“We heavily invest in always-improving, best-in-class systems to combat it and safeguard artist payouts with strong protections like removing fake streams, withholding royalties, and charging penalties,” the Spotify spokesperson added.
Staton first dismissed the case on June 22 but allowed Collins to file a revised version.
He did so on July 13, as MBW reported.
That amended complaint cited Drake, noting that he had “once explained in a legal filing” that “[s]treaming and licensing is a zero-sum game.”
The same phrase appears in a petition filed in November 2024 by Drake’s company, Frozen Moments LLC.
That petition accused Universal Music Group and Spotify of a scheme to “artificially inflate” Kendrick Lamar’s Not Like Us, including through the use of bots. It also alleged that UMG charged Spotify licensing rates 30% below usual for the track in return for Spotify recommending it to users.
UMG called those allegations “offensive and untrue,” and Spotify said it had “no economic incentive for users to stream Not Like Us over any of Drake’s tracks.”
Drake later withdrew the petition and sued UMG for defamation, a case that was dismissed in October 2025 and is now on appeal, with oral argument set for December 4.
A separate proposed class action, accusing online casino Stake.us, Drake, and others of concealing that players’ money helped fund a “bot army,” was paused in July while the plaintiffs’ dispute with Stake goes to arbitration.
Stake has denied the allegations.Music Business Worldwide
