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Drake alleged that UMG used bots, paid promotion and a Spotify recommendation deal to boost Kendrick Lamar’s “Not Like Us.” Those claims were never established in court: Drake withdrew the petition that named UMG and Spotify, then filed a separate defamation lawsuit against UMG. A federal judge dismissed that case in October 2025, finding the song’s challenged statements were opinion in context and the pleaded stream-manipulation theory insufficiently plausible.
What did Drake allege about “Not Like Us”?
In November 2024, Drake’s company, Frozen Moments LLC, filed a New York petition seeking pre-action discovery and preservation of evidence from Universal Music Group (UMG) and Spotify. It alleged that UMG used bots, pay-to-play arrangements, paid influencers and other promotional methods to increase the song’s reach. The petition also alleged, on information and belief, that UMG offered Spotify a discounted licensing rate in exchange for recommending “Not Like Us.” These were allegations, not court findings. The claims are described in the Associated Press’s report and in UMG’s response to the petition.
UMG denied wrongdoing. In its response, the company called the claims speculative and disputed that it had made the alleged Spotify deal. UMG also said, “We employ the highest ethical practices in our marketing and promotional campaigns.” The AP reported UMG’s position that fans, rather than the company, choose what music they hear. Those statements are UMG’s response, not independent findings about how the song was promoted.
Were the petition and the lawsuit the same case?
No. The petition was a request to obtain and preserve information before a possible lawsuit; it was not the later federal defamation case. Drake withdrew the petition on January 14, 2025. The next day, he filed a separate lawsuit against UMG. Spotify was not a defendant in that federal case, and Kendrick Lamar was not a defendant either. Music Business Worldwide reported the withdrawal and new filing.
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| Proceeding | Named parties | Purpose or claim | Outcome |
|---|---|---|---|
| New York pre-action petition, November 2024 | Frozen Moments LLC sought information from UMG and Spotify | Seek discovery and preserve evidence concerning alleged promotion and stream boosting | Withdrawn January 14, 2025; the petition did not produce a finding that streams were manipulated |
| Federal defamation lawsuit, filed January 15, 2025 | Drake sued UMG; Spotify and Lamar were not defendants | Challenge UMG’s publication and promotion of the song, its lyrics, artwork and video | Dismissed by the district court on October 9, 2025 |
Why did the federal court dismiss Drake’s case?
On October 9, 2025, U.S. District Judge Jeannette A. Vargas granted UMG’s motion to dismiss the amended complaint. The court treated the challenged statements in “Not Like Us” as nonactionable opinion when heard in the context of a heated rap battle. Judge Vargas wrote: “Republication cannot transform Lamar’s statement of opinion into UMG’s statement of fact.” The opinion concluded that the battle’s “incendiary language and offensive accusations” would not lead a reasonable listener to take the song as imparting verifiable facts about Drake. Read the court’s October 9, 2025 opinion and order.
The judge also found the complaint’s theory of covert stream manipulation insufficiently plausible as pleaded. The opinion said the allegations relied on online posts and fan reporting to infer manipulation. Dismissal on a motion to dismiss is a legal ruling on the complaint’s sufficiency, not a trial finding after discovery that established whether streams were or were not manipulated.
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Do the stream counts prove that streams were inflated?
No. The court opinion recounts the numbers as Drake’s allegations or arguments, not as proof of artificial activity:
- The amended complaint alleged that “Not Like Us” had more than 1.4 billion Spotify streams globally as of April 2025. The opinion attributes that figure to the complaint; a high stream count does not establish that streams were generated artificially.
- At oral argument, Drake argued that the song reached 300 million Spotify streams in 35 days. That was his argument, not a judicial finding that bots or paid promotion caused the streams.
The court opinion does not find that UMG or Spotify manipulated the song’s streams. It addresses the legal claims and allegations before the court, not a verified measurement of manipulation.
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What happened after the dismissal?
Pitchfork reported on January 22, 2026, that Drake had filed an opening appellate brief seeking reversal of the dismissal. The report quotes Drake’s lawyers continuing to argue that UMG promoted false and defamatory insinuations. That report establishes that an appeal was being pursued at that time; it does not establish the appeal’s later status or outcome. Pitchfork’s report is dated January 22, 2026.
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