A federal judge has dismissed with prejudice a lawsuit alleging that Spotify allowed bot-assisted fraudulent streams for major artists such as Drake. Because the dismissal is with prejudice, the case cannot be refiled.
Second dismissal in the same case
The case was first dismissed earlier this year without prejudice and was then refiled. The same judge has now dismissed it again on similar grounds.
The court ruled that rapper RBX, whose real name is Eric Dwayne Collins, offered only vague, conclusory claims. It also found no evidence that Spotify violated California’s Unfair Competition Law.
RBX filed an amended complaint within the 20-day window set by the court. Judge Stanton again found the claims vague and conclusory, and ruled that Spotify had no legal obligation to protect him from bots on its platform. She also found no evidence that Spotify made deceptive claims about its anti-fraud policies.
What the lawsuit alleged
In his initial filing, RBX accused Spotify of ignoring fraudulent streams. He named Drake as an artist who, he claimed, received a “non-trivial percentage” of his 37 billion-plus streams from “a sprawling network of Bot Accounts.”
The suit challenged Spotify’s payout model, which is based on an artist’s share of the platform’s total streaming count. If the allegedly fraudulent streams affected that share to the extent RBX claimed, it would result in “hundreds of millions of dollars” in falsely earned royalties for top artists such as Drake.
