RBX v. Spotify, two-tier streaming fraud class action

Background

RBX, the West Coast rapper Eric Dwayne Collins, filed a proposed class action against Spotify in November 2025 in the Central District of California, alleging the platform's anti-fraud program is "nothing more than window dressing." The suit pleads negligence and unfair competition rather than copyright, and names only Spotify as a defendant.

The theory is not that streaming fraud exists, which Spotify concedes and says it spends heavily to fight, but that enforcement is selective. Collins alleges Spotify "intentionally ignores fraud committed by certain 'a-list' artists," so that manipulated plays for top-tier acts are counted as legitimate while comparable activity around independent artists is stripped out. Because Spotify pays from a finite royalty pool divided pro rata, every uncancelled fraudulent stream on a superstar's catalog mathematically shrinks everyone else's share. The complaint puts the scale at "at least $600 million in royalties" diverted over a nearly 48-month period through 2025, based on its own analysis of streaming activity.

Much of the pleading concerns Drake. It alleges suspicious accounts streamed his catalog for roughly 23 hours a day and that traffic originating in Turkey was geomapped to the United Kingdom. Drake is not a party.

On June 22, 2026, Judge Josephine Staton dismissed the complaint. She held that Collins had not established that Spotify owed him a duty to protect him from third-party bot activity, and questioned the case's heavy focus on an artist who was not a defendant. She granted leave to amend, and Collins filed an amended complaint in late July 2026 that leans harder on the disclosure theory: that by "representing that it evenhandedly protects the integrity of its music royalty ecosystem" while "selectively declin[ing] to police" superstar fraud, Spotify "created a false impression that it was safeguarding all rightsholders equally." Spotify called the amended filing baseless on July 30 and said it will move to dismiss.

Why It Matters for Artists and Fans

Pro rata payout is the quiet mechanic behind almost every streaming grievance: there is one pot, and a stream that should not have counted is money taken from someone who earned theirs. This case asks whether a platform that markets itself as the referee can be held to that claim in court, or whether the relationship between a distributor's artists and the service is too attenuated to create any duty at all. The first ruling suggested the latter, which is the same wall independent artists keep hitting elsewhere. It also sits alongside Kratter v. Spotify, filed months later on the mirror-image complaint that Spotify's undisclosed filtering rules strip legitimate streams from small catalogs. Between them, the two cases allege that discretion runs in one direction: generous at the top, strict at the bottom.