Rapper RBX Appeals Following Spotify Fraud Lawsuit Dismissal

The Richard H. Chambers U.S. Court of Appeals. Photo Credit: Coolcaesar

Last month, a federal judge dismissed a fraud-focused class action filed against Spotify by rapper Reality Born Unknown (RBX). Now, the “Heatmizer 2” artist has kicked off an appeal.

Long Beach-born RBX (real name Eric Collins) and his legal team made the Ninth Circuit appeal official in a concise notice. When the main filing hits the docket, we will, of course, know substantially more about Collins’ precise arguments.

But we aren’t without information about his broader claims at present. Following a dismissal setback, RBX over the summer submitted an amended complaint accusing the DSP of failing to curb bot-powered fraud at the expense of non-major-label artists.

In a nutshell, Spotify is allegedly rather aggressive in sniffing out manipulation on indie releases. At the same time, the service allegedly fails to crack down on fraud across the catalogs of commercially prominent acts including Drake – to the tune of over $600 million in allegedly diverted royalties, per RBX’s suit.

As some will recognize, this isn’t the only complaint alleging fake streams on Drake’s catalog.

“Drake – acting directly and through willing and knowledgeable co-conspirators – has deployed automated bots and streaming farms to artificially inflate play counts of his music across major platforms, such as Spotify,” a subsequently decommissioned action alleged towards 2026’s start.

In general, however, these plaintiffs have had a difficult time getting their cases off the ground. Last month, the initially mentioned judge tossed RBX’s suit with prejudice, determining that he’d “failed to plausibly allege that Spotify has an undisclosed selective (anti-fraud) enforcement policy.”

“(T)he Court finds Plaintiff’s allegations that Spotify ‘chose to selectively enforce’ its existing artificial streaming infrastructure against certain artists, but not others, to be entirely conclusory and unsupported,” Judge Josephine Staton continued.

On one hand, that the relevant defendants have effectively shrugged off fraud-focused suits definitely isn’t a positive for the filing parties. On the other hand, the early dismissal trend means pressing questions remain about the largely unexplored allegations themselves.

With that, it’ll be worth tracking RBX’s appeal moving forward. Closer to the present, the available evidence suggests that a number of legitimate artists may be getting caught in the crossfire amid Spotify’s anti-spam crackdown.

Meanwhile, with fake plays reaching the overwhelming majority of gen AI uploads – as fans grow increasingly tired of encountering machine-generated slop – Deezer is prepping an AI audio on/off toggle, and YouTube Music is now labeling AI outputs.