Michael Smith was sentenced to 18 months in prison on October 6, 2026, after pleading guilty to conspiracy to commit wire fraud in a scheme involving AI-generated music and automated streams. The $10 million figure came from the 2024 charging allegation; later court-outcome announcements reported more than $8 million in royalties and $8,091,843.64 in forfeiture.
What happened in the music-streaming fraud case?
Federal prosecutors alleged in 2024 that Smith’s scheme ran from about 2017 through 2024. According to the indictment, he obtained hundreds of thousands of AI-generated songs, uploaded them to major music services and used automated programs to play them billions of times. The indictment also alleged that he created false accounts, misrepresented who controlled them and spread the activity across a large catalog to avoid drawing attention to individual tracks. These details describe the original allegations; Smith later pleaded guilty to one count of conspiracy to commit wire fraud.
The indictment named Amazon Music, Apple Music, Spotify and YouTube Music among the services involved. Their appearance in the case account does not establish individual loss totals or mean the platforms had identical policies. The 2024 charging announcement and the indictment describe the allegations.
How the alleged operation generated fake plays
In its October 2026 sentencing announcement, the U.S. Attorney’s Office said Smith used as many as 10,000 bot accounts at once. DOJ said fake email accounts and fraudulently obtained debit cards were used to create accounts, and activity was spread across thousands of songs. These are details from DOJ’s account of the sentenced case.
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To illustrate the scale, DOJ said Smith’s AI-generated music received 80.9 million alleged bot-account streams on YouTube Music in April 2023, compared with 9.3 million streams for Taylor Swift’s entire catalog on YouTube Music’s family plan that month. That comparison is specific to the platform, month and figures reported by DOJ; it is not a general comparison of artists’ audiences.
How fake streams can affect royalty payments
Streaming services provide usage and revenue data that rights organizations use to allocate royalties. The indictment describes two broad rights categories: composition royalties for songwriters and sound-recording royalties for artists. It says both may be distributed proportionally according to streaming activity. When fake plays are counted as if they came from listeners, they can make a track appear to have earned a greater share of a royalty pool, reducing the share available to works that people actually streamed.
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The U.S. Copyright Office also describes illegitimate streams as diluting royalty pools for legitimately streamed works. Its Music Streaming Fraud page discusses bot farms, click farms, playlist stuffing and account hijacking as forms of streaming fraud, and says prevention efforts have had varying success.
There is no single guaranteed payout for a stream. The 2024 indictment says the amount varies with multiple factors and is often less than one cent per stream; that is context from a court filing, not a universal current rate.
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How the case changed from allegation to sentence
| Date and stage | What officials reported | How to interpret it |
|---|---|---|
| September 4, 2024: indictment and charging announcement | More than $10 million was alleged. | This was the government’s allegation at charging, not the later forfeiture figure. |
| March 19, 2026: guilty plea | Smith pleaded guilty to one count of conspiracy to commit wire fraud. DOJ described more than $8 million in royalties and said he agreed to pay $8,091,843.64 in forfeiture. | The plea was to one count; the original indictment’s three counts should not be described as convictions. |
| October 6, 2026: sentence | DOJ reported 18 months in prison, two years of supervised release and an order to pay $8,091,843.64 in forfeiture. | The announcement establishes the order, not that the forfeiture has been collected. |
The guilty plea announcement is available from the U.S. Attorney’s Office for the Southern District of New York; its sentencing announcement was updated October 6, 2026.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the case does—and does not—say about streaming fraud policy
The Copyright Office has opened a notice of inquiry into streaming fraud, including its prevalence, effects on the industry, existing countermeasures and possible solutions. The office’s page lists initial comments due November 23, 2026, and reply comments due December 21, 2026. These are comment deadlines, not findings or enacted rules.
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The office says digital music providers, distributors, vendors, rights holders, performance rights organizations, collective management organizations and law enforcement have taken steps to prevent fraud, with varying success. The cited page does not endorse a particular prevention product. Nor do the DOJ releases establish individual loss totals for each named platform or provide detailed reasoning from the sentencing judge.
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