Judge dismisses Spotify lawsuit over alleged Drake bot streams

By Elena Vasquez

According to a 16-page ruling obtained by Rolling Stone, U.S. District Judge Josephine L. Staton permanently dismissed RBX’s Spotify lawsuit on Friday. The proposed class action, first reported by Rolling Stone last November, accused Spotify of “turning a blind eye” to billions of allegedly fraudulent Drake streams.

What did the court decide about Spotify?

Staton found that RBX failed to establish a specific legal duty owed by Spotify. She also found that he failed to allege the type of harm necessary for negligence. Staton said the pleading did not support claims that Spotify unfairly enforced its rules, committed fraud, or harmed consumers or competitors.

Staton wrote: “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,” she said. She said the allegations instead showed a “mutually beneficial economic” relationship between RBX and Spotify. Staton acknowledged a power imbalance typical of dealings between corporations and individuals.

Staton had previously dismissed the lawsuit and allowed Collins to amend it. She then dismissed the case with prejudice, which prevents Collins from refiling the same claims in federal court.

“After granting leave to amend once, and considering the additional facts alleged in the [first amended complaint], the court has found no reason to depart from its prior conclusions,” Staton wrote.

Plain takeaway: the amended complaint still failed to connect the alleged bot streams to a legal duty Spotify owed RBX.

How did Spotify royalties allegedly reward bots?

Collins, a cousin of Snoop Dogg, alleged in his complaint that a “substantial, non-trivial percentage” of Drake’s approximately 37 billion streams were “inauthentic and appeared to be the work of a sprawling network of bot accounts.” He claimed the scale of the alleged bot network threatened royalty income for legitimate artists.

His argument relied on Spotify’s “streamshare” model:

• Subscription and advertising revenue first forms a shared pool.
• Artists receive distributions according to their share of total streams.
• Artificially inflated streams can increase one group’s claim on that pool.

Collins argued that inflated streams allowed some artists to claim a disproportionate share of the money. He said the mechanism reduced the royalties available to artists with legitimate streams.

Drake was not named as a defendant in the Spotify case. A representative for RBX, the “Nokia” rapper, declined to comment on Monday. Lawyers for Collins and Spotify did not immediately respond to requests for comment.

Plain takeaway: Collins framed bot traffic as a royalty-distribution problem, but the court found his pleading legally insufficient.

What remains in the separate Virginia bot-and-gambling case?

The latest Spotify ruling came three months after a federal judge in Virginia paused a separate lawsuit. The case accuses Drake, whose legal name is Aubrey Graham, and streamer Adin Ross of using Stake.us to bankroll a “bot army” that allegedly inflated Drake’s music streams.

On July 30, the judge stayed the case pending arbitration between Stake and the plaintiffs. The judge said the litigation would remain on ice during that process.

The plaintiffs allege a conspiracy to “prey upon consumers,” expose them to “substantial risks of gambling addiction,” and jeopardize their financial well-being. They claim they were “influenced to participate” in Stake’s allegedly predatory gambling operation after viewing Drake’s paid promotions. Those promotions included livestreamed gambling sessions and giveaways.

A Drake representative declined to comment when Rolling Stone reported the original lawsuit.

Plain takeaway: the Virginia claims remain unresolved, and the next stage will come only if the case proceeds after arbitration.