As reported by Billboard — the same article used as the basis for the motion — the settlement agreement calls for Spotify to pay NMPA $30 million in return for waiving any claims related to the alleged infringement and royalties due. But the plaintiffs say they are "gravely concerned" that Spotify and the NMPA are not communicating to class members their rights not to waive their litigation rights. Spotify has blamed unpaid royalties on "often missing, wrong, or incomplete" data necessary to pay rights holders and claims it sets aside unpaid royalties until songwriters are identified.