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Judge Dismisses RBX’s Bot-Farming Class Action Against Spotify

6/24/2026, 5:13:07 AM

Court Dismisses Bot-Farming Class Action

On June 22, 2024, U.S. District Judge Josephine Stanton dismissed the class-action suit filed by rapper RBX against Spotify, finding the complaint insufficient to show that alleged bot-generated streams caused measurable harm.

Streaming Royalties and Bot-Farming Concerns

Spotify’s royalty system allocates payouts based on each artist’s share of total platform streams. Artificial streams can inflate a top artist’s share, potentially reducing earnings for lower-profile creators, a concern long raised by industry observers.

Key Figures & Groups

The plaintiff, RBX (Eric Brock), claims the alleged fraud harms independent musicians. Spotify is the defendant. Judge Stanton presided. Drake, whose catalog accounts for billions of streams, is cited as an example of an artist who may benefit from artificial plays, though he is not a defendant.

Data & Statistics

The complaint points to Drake’s 37 billion streams, asserting a “non-trivial percentage” stems from a “sprawling network of Bot Accounts.” It estimates that artificial streams divert “hundreds of millions of dollars” from royalty pools meant for smaller creators. The judge gave RBX 20 days to amend the filing.

Official Statements & Responses

Judge Stanton concluded that RBX had not demonstrated that any alleged artificial streams caused sufficient harm to outweigh Spotify’s policy justifications, and she noted that the complaint centered on a single artist, making the broader injury claim unclear. Spotify has not issued a public comment.

Criticism & Opposition

RBX’s legal team argues that bot-generated streams inflate top-artist shares, reducing royalty payouts for independent musicians. The suit frames the practice as a violation of California’s Unfair Competition Law, alleging that Spotify’s inaction enables market distortion.

Conflicting Reports & Gaps

The lawsuit provides no concrete evidence linking specific bot accounts to Drake’s streams, and the judge noted the absence of a demonstrated duty for Spotify to police such activity. Consequently, the exact financial impact on smaller artists remains unverified.

Verbatim Quotes

  • “failed to plausibly allege that the harm he has suffered outweighs any justification Spotify may have for maintaining its current policies regarding artificial streaming.” — Judge Josephine Stanton
  • “Plaintiff’s complaint focuses almost exclusively on the artificial streams of only one artist’s music,” — Judge Josephine Stanton
  • “non-trivial percentage” of Drake’s 37 billion total streams “appeared to be the work of a sprawling network of Bot Accounts.” — Complaint (RBX v. Spotify)
  • “hundreds of millions of dollars” — Complaint estimate of diverted royalties

What’s Next

RBX plans to file an amended complaint within the 20-day deadline, and separate litigation by Drake against Spotify and Universal Music Group over alleged stream-boosting continues, indicating ongoing scrutiny of artificial streaming practices.