Spotify wins dismissal of lawsuit claiming it allowed ‘billions’ of fraudulent Drake streams

A US federal judge has dismissed a proposed class action that accused Spotify of allowing billions of bot-generated fake streams to inflate the play counts of Drake and other artists.

Judge Josephine Staton, of the US District Court for the Central District of California, granted Spotify‘s motion to dismiss on Monday (June 22), in a ruling, which you can read here.

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 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 – whom 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.” Drake passed 120 billion all-time Spotify streams in September 2025, becoming the first artist to do so.

Drake was not named as a defendant in the suit, nor accused of any wrongdoing.

The complaint alleged, for example, that bots used VPNs to disguise the origin of streams, with 250,000 plays of the Drake track No Face over a four-day period in 2024 routed from Turkey but mapped to the United Kingdom.

In dismissing the negligence claim, 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.”

Staton also questioned the complaint’s near-exclusive focus on a single artist, finding it unclear how far Collins himself had been injured by artificial streaming across the platform.

The judge dismissed both of Collins‘s claims but granted him leave to amend.

Responding to the lawsuit, a Spotify spokesperson said in November that the company “in no way benefits from the industry-wide challenge of artificial streaming.”

“We heavily invest in always-improving, best-in-class systems to combat it and safeguard artist payouts with strong protections like removing fake streams, withholding royalties, and charging penalties,” Spotify said.

The company pointed to the case of Michael Smith, the North Carolina musician indicted in 2024 over a streaming-fraud scheme, noting that only around $60,000 of the $10 million he was alleged to have generated came from Spotify.

The dismissal lands amid a run of litigation in which Drake‘s streaming numbers have been scrutinized from more than one direction.

In November 2024, Drake – via his company Frozen Moments LLC – filed a petition accusing Universal Music Group and Spotify of a scheme to “artificially inflate” Kendrick Lamar‘s diss track Not Like Us using bots.

UMG called the allegations “offensive and untrue,” and Drake withdrew the petition before suing UMG for defamation in January 2025.

A New York judge dismissed that defamation suit in October 2025, ruling Not Like Us protected opinion rather than actionable defamation, and Drake is appealing.

Collins‘s case was not the only November 2025 class action referencing Drake.

That same month, Spotify subscriber Genevieve Capolongo sued the company over its Discovery Mode feature, which she called “modern payola,” alleging her recommendations were dominated by the likes of Drake, Zach Bryan, and Justin Bieber.

A New York judge sent that case to arbitration in April 2026, dismissing Capolongo‘s class claims with prejudice.

Deezer, the French streaming service, reported in April that close to 75,000 fully AI-generated tracks were being uploaded to its platform every day, more than 44% of all new music.

Deezer said 85% of the streams of those AI-generated tracks were detected as fraudulent and stripped from royalty payments.

Collins has 21 days to file a revised complaint, or the case will be closed.Music Business Worldwide