According to Music Business Worldwide, a U.S. federal judge has dismissed proposed class action that accused Spotify of allegedly allowing billions of bot-generated fake streams to allegedly inflate the play counts of Drake and other artists. The case was brought by Eric Dwayne Collins, the rapper known as RBX, who claimed Spotify‘s failure to curb “mass-scale fraudulent streaming” had allegedly stripped royalties from other rights holders.
Filed in November 2025, the complaint alleged that “Every month, under Spotify’s watchful eye, billions of fraudulent streams are generated from fake, illegitimate and/or illegal methods.” The suit pointed to Drake, who is the complaint describes as Spotify’s most-streamed artist of all time, as its central example. Collins alleged that a substantial percentage of the roughly 37 billion streams Drake accumulated on Spotify between January 2022 and September 2025 were inauthentic and “appeared to be the work of a sprawling network of bot accounts.”
In dismissing the negligence claim, Judge Josephine Staton found that Collins had not shown Spotify owed him a legal duty to protect him from third-party bots. The judge also rejected his claim under California‘s Unfair Competition Law. In her ruling, Staton wrote that Collins “has failed to plausibly allege that the harm he has suffered outweighs any justification Spotify may have for maintaining its current policies regarding artificial streaming.”
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