Photo Credit: Theo
Spotify is victorious once again as a federal judge dismisses a class action bot-fraud case, finding no evidence that Spotify violated California law.
A federal judge has dismissed a lawsuit that alleged Spotify was allowing rampant bot-assisted fraudulent streams for major artists like Drake. The case was initially dismissed earlier this year without prejudice but was then refiled. Now, the same judge has dismissed the case again on similar grounds, ruling that rapper RBX only offered vague, conclusory claims about the matter and that there was no evidence that Spotify violated California’s Unfair Competition Law. This time, the case has been dismissed with prejudice, meaning it cannot be refiled.
In his initial filing, RBX (whose real name is Eric Dwayne Collins) accused the company of ignoring fraudulent streams and specifically named Drake as a major artist whom he claimed received a “non-trivial percentage” of his 37 billion-plus streams from “a sprawling network of Bot Accounts.” The lawsuit called into question Spotify’s controversial payout model, which is based on an artist’s share of the platform’s total streaming count. This amount, if impacted by the allegedly fraudulent streams to the extent RBX claimed, would lead to “hundreds of millions of dollars” in falsely earned royalties for heavy-hitters like Drake.
However, Judge Stanton ruled back in June that RBX “failed to plausibly allege that the harm he has suffered outweighs any justification Spotify may have for maintaining its current policies regarding artificial streaming.” The court found insufficient evidence to support the claims that Spotify was negligent in protecting artists from fraud and that the company violated California’s Unfair Competition Law.
RBX and his team quickly refiled an amended complaint within the 20-day window designated by the court. Now, Judge Stanton has once again ruled that the rapper’s case has only provided vague, conclusory claims about the matter and that Spotify had no legal obligation to protect him from bots on its platform. She also found no evidence that Spotify had violated California’s Unfair Competition Law or made deceptive claims regarding its anti-fraud policies.
Although the case is now permanently shut, the matter still draws into question exactly what Spotify knows and allows on its platform when it comes to artificially inflated streams—an issue that has long been debated in the streaming age.