Judge Josephine Staton dismissed the revised case with prejudice after finding insufficient allegations of wrongdoing, preventing RBX from amending this complaint again in the trial court.
Federal Judge Josephine Staton dismissed rapper RBX’s revised lawsuit against Spotify with prejudice on October 26, 2026. The ruling ends this complaint in the trial court rather than allowing another revision. Billboard first obtained and reported the ruling.
RBX, whose name is Eric Collins, filed the lawsuit in 2025. He alleged that Spotify tolerated fraudulent plays benefiting major artists and deprived tens of thousands of other artists of fair royalties. The judge had dismissed an earlier version as too vague but gave him a chance to fix its deficiencies.
Staton said the revised lawsuit still did not explain how Spotify selectively enforced its rules against artificial streaming. General assertions that the company ignored fake plays for popular artists such as Drake were not enough to plausibly allege legal wrongdoing.
She rejected the negligence claim because Spotify owed RBX no special duty to protect him from bots—automated systems used to generate plays. His weaker position in the music industry did not, by itself, establish a relationship in which Spotify had to protect him.
Staton also rejected the claims under California’s Unfair Competition Law. She found that RBX had not plausibly alleged deceptive statements about Spotify’s anti-bot policies or unfair enforcement of those policies that harmed him.
Streaming fraud inflates song-play totals through illicit means. Because streaming services distribute royalties among rights holders from a limited pool, fraudulent plays can divert money from legitimate listening. RBX’s lawyers alleged that Spotify’s anti-fraud policies were merely for show and that bots benefited the company financially.
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Spotify has said it invests heavily in detecting, removing and penalizing fake streams. The company declined to comment on the ruling.
RBX’s lawyers alleged that Drake’s songs received billions of fraudulent streams, but Drake was not a defendant and that allegation was not established by the ruling. The dismissal addresses whether RBX adequately alleged unlawful conduct by Spotify; it does not establish that fraudulent streams do not exist. Its immediate effect is to bar another amended version of this complaint in the trial court.
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