Spotify bot-farming lawsuit gets dismissed by California judge

Bot farming is as much a part of the modern music industry as fake, publicist-run fan accounts—which is to say, too much. But given that rapper RBX’s class-action lawsuit against Spotify’s lax bot farming policies has just been dismissed in a California federal court, it’s not looking like that will change anytime soon.

RBX accused the streaming service of active negligence in the face of the corruption and exploitation of its payout model by bot farms. Artificially-inflated streaming numbers result in much higher royalties for the artists that benefit from them, thus causing “massive financial harm” to all other “legitimate artists” and rights-holders. There’s only a finite amount of royalties, after all, so the more allocated to one artist, the less available to be allocated to others. Fake streams, then, divert revenue from actual streams of smaller artists to larger artists who boast inauthentically boosted numbers. The suit argued that Spotify’s anti-fraud rules were “inadequate at best,” and the service was willfully turning a “blind eye” to those who game the system.

At the time of filing, Spotify put out a statement insisting that it “in no way benefits from the industry-wide challenge of artificial streaming” and has put into place “best-in-class systems to combat it.” RBX’s lawyers did not buy the claim that Spotify had nothing to gain from fake streams, and wrote that “The more users (including fake users) Spotify has, the more advertisements it can sell, the more profits the company can report, all of which serves to increase the purported value delivered to shareholders.”

But in yesterday’s decision, Judge Josephine Stanton declared RBX’s accusations were too “vague” and non-specific to present a viable case. As she put it in the decision, “Plaintiff 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.” Concerningly, Stanton rejected the accusations of negligence, saying that RBX failed to prove that Spotify had any duty to protect him, or artists in general, from bots in the first place. 

She also ruled that the suit’s claims of Spotify violating California’s Unfair Competition Law were unfounded, although her argument there had more to do with the details of the suit itself. For some reason, it focused less on artificial streaming in general and more on the role it’s played in one artist’s career—Drake. The lawsuit claimed that Spotify allows bots to boost Drake’s streams by the billions, specifically citing a period in 2024 when around 250,000 streams of “No Face” were registered via VPN in the UK but could be geo-mapped back to Turkey. Although the Drake example was presumably used as evidence to showcase how smaller rappers are being deprived of fair royalties, Judge Stanton did not find it compelling enough and wrote in her decision: “Plaintiff’s complaint focuses almost exclusively on the artificial streams of only one artist’s music, so the extent to which plaintiff is injured by artificial streaming as a whole is unclear.”

All is not lost quite yet, though: Judge Stanton has given RBX a chance to refile the case in the next 21 days with amendments addressing the issues referenced in her decision. According to Billboard, his lawyers have confirmed they plan to do so but have not commented further.

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