A Spotify user, Genevieve Capolongo, who sued the company over accusations that Discovery Mode is a "modern form of payola," cannot pursue these claims in federal court under the terms of service, as all Spotify users waive any right to sue the company when they sign up for the service. However, a federal judge has ruled that such disputes must instead be handled via private arbitration. The ruling was made by Judge John G. Koeltl, who stated that the arbitration agreement was unenforceable due to several reasons including that Capolong had signed a user agreement stating that her claims were against the company. The case was one of several filed last year to claim that major labels are buying placement on Spotify to boost their artists.