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Spotify CEO pleads for iPhone users to stop paying through Apple's App Store

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KHarvey16

Member
S¡mon;171540206 said:
Man, still enough people here defending Apple.

If your argument is "well, Apple charges 30% for all apps, it's their platform, so that's that"... okay, but in my opinion everything changes as soon as Apple becomes a direct competitor.

Apple has an audience of hundreds of millions, if not over a billion, people worldwide. They are now starting to offer a music streaming service at $9.99, while all their competitors are forced to charge almost 30% extra to make the same amount of revenue. In my opinion, a 30% cut is exorbitant. It is anti-competitive (it is literally impossible for competing music streaming services to make the same amount of revenue at the same price) and it can be anti-consumer as it can lead to up to 30% higher prices.

Just my two cents.

What about things like fees on consoles for third party developers? Or even store brand groceries? I can't see how any third party could ever feel entitled to the infrastructure and associated user base a proprietary platform holds. It's apple's audience, who have all opted in to that ecosystem.
 

Slavik81

Member
Amazon doesn't give Apple a cut with Option B either.

So it comes down to, do customers really bail on a purchase because they have to buy their content on a different Amazon app/website instead of the iOS app? I believe the answer to that is "no". Not in a meaningful amount, anyway. If someone decides to buy something, they're going to buy it.
I'm almost certain you're incorrect. Companies do extensive testing of their signup pages because tiny differences in the amount of effort it takes to register can result in large differences in the total number of signups.

Especially early on, companies may have employees working full-time on changing small things about the signup page and collecting statistics about the number of signups they get doing it one way vs. doing it another.
 
D

Deleted member 12837

Unconfirmed Member
I'm almost certain you're incorrect. Companies do extensive testing of their signup pages because tiny differences in the amount of effort it takes to register can result in large differences in the total number of signups.

Especially early on, companies may have employees working full-time on changing small things about the signup page and collecting statistics about the number of signups they get doing it one way vs. doing it another.

You're 100% correct about registrations, but buying a book is not the same thing as signing up for a new service you're discovering for the first time at that moment.

I don't randomly surf the iOS Kindle App for books to impulse-buy, but maybe that's something a ton of people do?

I'd think apps like Kindle, Audible, Comixology, etc are app first services though and Apple's policies applies to services like them too.

See above. Those are things that I'd consider mostly "premeditated" purchases (more often than not, anyway), but maybe I'm out of touch and that doesn't reflect the dominant purchase pattern these days.

Heh, you'd think how some people piss on Android being janky because Apple does it better than every experience worse is considered janky. I'd agree though that there are varying degrees of difference in quality in experience. I'd also say in this case, Apple's implementation of not using Apple's IAP is janky especially since they won't even allow a link in the app. A link in the app would make it much less janky than it is now.

Yeah the Android criticisms are unfounded, for sure. And allowing links in the app would go a long way to a smoother experience as a compromise, yes.
 

borghe

Loves the Greater Toronto Area
S¡mon;171540206 said:
okay, but in my opinion everything changes as soon as Apple becomes a direct competitor.
This argument looks good on paper, I'll give you that. The problem arises when you consider the opposite path. What happens when Apple exists in a market, but then a competitor enters it on Apple's sales platform? Is Apple then immediately required to "level the playing field" for that competitor? Or exit entirely?

Take the iTunes Store? It was available on iPhone before the first music app even became available on iOS. Apple wasn't locking anyone out. So then a couple years later Pandora and Spotify go app with paid options. How far as Apple expected to accommodate them to not be "anti-competitive"?

Ultimately I find all of this anti-competitive talk misguided and misrepresented. Apple and Amazon with the IAP listing parity, THAT is the closest you will find to truly anti-competitive, and even then Apple was never found guilty by the DOJ or EU to be charged/fined for. Obviously the ebook price fixing, which they WERE found guilty of. But everything being talked about in the OP is the price of doing business. Nothing at all worse than Tide detergent and Tombstone pizza having to sit on the shelves in the store right next to the generic store brands. Hell, the only reason this even catches a glance AT ALL is because Google's policy allows publishers to avoid it on the largest competing platform. Still, that hardly sets precedent here. So Target shouldn't get a cut from selling Tide brands to keep things even? What about companies selling cables on Amazon? Should Amazon wave their wholesale payments so those companies can sell their cables for the same margin that Amazon sells their Basics cables for?
Yeah the Android criticisms are unfounded, for sure. And allowing links in the app would go a long way to a smoother experience as a compromise, yes.
I won't argue that it could be better, but who's asking for it the loudest? History has shown that when it's harder to get something in app, the consumer will bitch at the developer, not Apple. After all, it's not Apple keeping the IAP out of the app store, and the dev certainly can't say it is. So the loudest noise to change the policy is from the devs themselves. Yet as we know from earlier links, not only is the App Store significantly higher revenue per download average, but we know total revenue and average revenue per download are both growing over Google Play. So if the users aren't asking for Apple to change the policy, and the devs are in fact making more money on the platform despite the policy being in place, it's really hard to look at things and feel bad for those who participate. Well unless you own stock or work for one of the devs.
 
Ultimately I find all of this anti-competitive talk misguided and misrepresented. Apple and Amazon with the IAP listing parity, THAT is the closest you will find to truly anti-competitive, and even then Apple was never found guilty by the DOJ or EU to be charged/fined for. Obviously the ebook price fixing, which they WERE found guilty of. But everything being talked about in the OP is the price of doing business. Nothing at all worse than Tide detergent and Tombstone pizza having to sit on the shelves in the store right next to the generic store brands. Hell, the only reason this even catches a glance AT ALL is because Google's policy allows publishers to avoid it on the largest competing platform. Still, that hardly sets precedent here. So Target shouldn't get a cut from selling Tide brands to keep things even? What about companies selling cables on Amazon? Should Amazon wave their wholesale payments so those companies can sell their cables for the same margin that Amazon sells their Basics cables for?

This comparison if physical goods seems way off to me. Companies who develop products hardly ever sell direct to consumers. They sell to stores at wholesale and their business is built around that. What the store does afterwards with the product is on them at that point since in most cases the company has their money already. There are of course different methods of distribution like consignment, minimum advertised prices and so forth that change that, but physical goods business is built around the wholesale model and then the stores can put it on sale, sell it at MSRP, etc. Target selling something at cost means Target doesn't make money, not the company who makes and distributes the product to the store.

Also you bring up Tide and Target which is an interesting case because I do believe Tide pays a premium and has an agreement with Target to take up a significant amount of shelf space which crowds out the competition. That's why when you go to Target you'll see a majority of the shelf space dedicated to Tide products.

This all is different when comparing it to the digital world though especially when it comes to services not being hosted or facilitated by Apple. One could even argue once you get the app, you're no longer in the store. Unless Apple is going to also be responsible for everything every app does too which I'm sure Apple doesn't want that liability.
 

S¡mon

Banned
What about things like fees on consoles for third party developers? Or even store brand groceries? I can't see how any third party could ever feel entitled to the infrastructure and associated user base a proprietary platform holds. It's apple's audience, who have all opted in to that ecosystem.

The big difference for fees on gaming consoles (for third party developers) is that they aren't directly competing with the manufacturer. It is not like Activision is publishing "Call of Duty: Green Ops", while Microsoft is publishing a nearly-identical "Call of Duty: Orange Ops". When Microsoft publishes a game on its console, the goal is to generate hardware sales so the Xbox-platform becomes in fact more interesting for third party developers.
When Microsoft publishes a game, it actually is in the interest of third party developers (hardware sales generate bigger audiences for third party devs).

Also, I am not saying Apple isn't allowed to take a small percentage to run the App Store, run the platform, manage payments, etc. - but 30% is exorbitant and not good for competition.

[]
This argument looks good on paper, I'll give you that. The problem arises when you consider the opposite path. What happens when Apple exists in a market, but then a competitor enters it on Apple's sales platform? Is Apple then immediately required to "level the playing field" for that competitor? Or exit entirely?
First of all, thank you for your reaction. You do, indeed, raise some good questions.

In the current situation (Apple entering the streaming market), I feel like stuff should change. As I mentioned, I feel taking a 30% cut is an exorbitantly high percentage and is not good for competition and might be bad for consumers.
If 30% is too much or is slightly subjective, but in my opinion it is. Apple is a multi-billion dollar company - it makes literally tens of billions of dollars of profit each year. And yet, with its policies, its basically strangling much smaller competitors.

As I said, you raise some interesting questions when it comes to competitors entering Apple's market, like the iTunes Store...

Take the iTunes Store? It was available on iPhone before the first music app even became available on iOS. Apple wasn't locking anyone out. So then a couple years later Pandora and Spotify go app with paid options. How far as Apple expected to accommodate them to not be "anti-competitive"?
I find it very hard to 'define' what Apple should do if competitors enter a market where Apple is already active in. To talk about the iTunes Store...

When the iTunes Store launched on the first iPhone, it was impossible for competitors to sell songs on the iPhone. There weren't even any third party apps! But the other thing is... Apple maybe owned 1% of the phone market in 2007. Even in 2008, when there were third party apps, and 2009... their market share wasn't that big.
If a company wanted to sell songs on the iPhone and Apple said "we won't allow that", well, at the time that would be fine. They were a relatively small player on the entire phone market. By 2010, iPhone sales only accounted for 4% of the entire market.

Fast forward to 2015: the entire phone market has grown and Apple's sales have exploded and they have an audience of hundreds of millions customers. If a company steps forward now, and wants to sell songs through an app on the App Store... than I feel like Apple can't be allowed to ask a 30% cut by default. They can ask a more fair and smaller cut to cover costs for the App Store... but 30% is too high. Competitors should be able to price match Apple's offerings.

Apple asking a 30% cut in 2008 is Apple being stubborn, but doesn't harm competition. Apple asking a 30% cut in 2015 is still Apple being stubborn, but now, I believe, it does harm competition and possibly consumers.

As I said, it is very hard to say what Apple should and shouldn't be allowed to do. But my opinion, right now, basically comes down to this: Apple has hundreds of millions of people that use their devices and they make tens of billions of dollars profit each year - that means Apple has a lot of power and influence. And, well, with great power come great responsibilities.
 

KHarvey16

Member
S¡mon;171544957 said:
The big difference for fees on gaming consoles (for third party developers) is that they aren't directly competing with the manufacturer. It is not like Activision is publishing "Call of Duty: Green Ops", while Microsoft is publishing a nearly-identical "Call of Duty: Orange Ops". When Microsoft publishes a game on its console, the goal is to generate hardware sales so the Xbox-platform becomes in fact more interesting for third party developers.
When Microsoft publishes a game, it actually is in the interest of third party developers (hardware sales generate bigger audiences for third party devs).

Also, I am not saying Apple isn't allowed to take a small percentage to run the App Store, run the platform, manage payments, etc. - but 30% is exorbitant and not good for competition.

Third party developers compete with first party developers in consoles the same way Apple competes with Spotify. Microsoft has Forza and third parties are also developing racing games. I can't see how you can differentiate those in any useful way in relation to the analogy.

30% is industry standard and not really that much when you consider what it's paying for. What percentage of the sale price do you think goes to the producer of anything sold through a third party? I think a publisher makes like $27 on a game sold for $60.
 

borghe

Loves the Greater Toronto Area
S¡mon;171544957 said:
As I said, it is very hard to say what Apple should and shouldn't be allowed to do. But my opinion, right now, basically comes down to this: Apple has hundreds of millions of people that use their devices and they make tens of billions of dollars profit each year - that means Apple has a lot of power and influence. And well, with great power comes great responsibilities.

I am going to exit this thread... agreeing with you. It IS hard to say what Apple should and shouldn't be allowed to do. Where does "it's fine for them to see money from it" and "they are harming competition" begin and end?

I'm pissed that Amazon removed IAP from Comixology... as a consumer I then had a choice.. buy from Comixology's web site, or buy from the individual publishers' own iOS apps. Amazon made the choice best for them, I made the choice best for me. This is the same give and take that producers, retailers and buyers go through EVERY day. I don't see why it should/would be any different here.
 
Here's a question for those who keep comparing it to Steam and game consoles; does anyone pay 30% of a monthly subscription fee for a mmo on Origin, Steam, OSX, Windows, PSN, or Xbox Live? Something tells me the answer is no.

I'm pissed that Amazon removed IAP from Comixology... as a consumer I then had a choice.. buy from Comixology's web site, or buy from the individual publishers' own iOS apps. Amazon made the choice best for them, I made the choice best for me. This is the same give and take that producers, retailers and buyers go through EVERY day. I don't see why it should/would be any different here.
But can't you see that it's Apple's policies that caused this?
 

xxracerxx

Don't worry, I'll vouch for them.
Here's a question for those who keep comparing it to Steam and game consoles; does anyone pay 30% of a monthly subscription fee for a mmo on Origin, Steam, OSX, Windows, PSN, or Xbox Live? Something tells me the answer is no.

I can't even fathom the uproar that would cause.
 

KHarvey16

Member
Here's a question for those who keep comparing it to Steam and game consoles; does anyone pay 30% of a monthly subscription fee for a mmo on Origin, Steam, OSX, Windows, PSN, or Xbox Live? Something tells me the answer is no.

I don't think you can pay for your mmo subscription using payment systems made for those platforms. You pay for WoW and then play it on windows, just like you can pay for Spotify and use it on your iPhone.
 
I don't think you can pay for your mmo subscription using payment systems made for those platforms. You pay for WoW and then play it on windows, just like you can pay for Spotify and use it on your iPhone.
So no mmo lets you pay within the game or asks for a cc when you first setup the game? You have to go to the game's website first to create and account and pay?
 

railGUN

Banned
So no mmo lets you pay within the game or asks for a cc when you first setup the game? You have to go to the game's website first to create and account and pay?

Does an MMO that lets you pay within the game, use the service you downloaded it from to process the charge, and handle any customer support that might arise from said payment?
 

KHarvey16

Member
So no mmo lets you pay within the game or asks for a cc when you first setup the game? You have to go to the game's website first to create and account and pay?

Personally I've never been able to setup an mmo account in-game, and I've used a few. But the comparison isn't that apt anyway since windows and the like aren't walled gardens and there is no windows payment infrastructure that gets used. Anyone can make hardware to run windows and anyone can sell software for the platform in whatever way they'd like. To utilize the steam infrastructure and reach the audience it provides, the publisher/dev is required to pay a portion of the proceeds to valve. I'm sure any third-party payment system charges fees for use as well.
 
Personally I've never been able to setup an mmo account in-game, and I've used a few. But the comparison isn't that apt anyway since windows and the like aren't walled gardens and there is no windows payment infrastructure that gets used. Anyone can make hardware to run windows and anyone can sell software for the platform in whatever way they'd like. To utilize the steam infrastructure and reach the audience it provides, the publisher/dev is required to pay a portion of the proceeds to valve. I'm sure any third-party payment system charges fees for use as well.

Well people keep making the comparison. Windows isn't a walled eco system, but the Windows app store is. Same with the OSX store. What's also a walled garden is PSN and Xbox Live. People keep comparing them to these services, but if you want to make the comparison you have to look at how they all handle subscription services. None of them take a 30% cut because none of them force them to use their service for subscriptions. Apple is the only one who does.
 

borghe

Loves the Greater Toronto Area
Here's a question for those who keep comparing it to Steam and game consoles; does anyone pay 30% of a monthly subscription fee for a mmo on Origin, Steam, OSX, Windows, PSN, or Xbox Live? Something tells me the answer is no.
Because you can't buy subscription time for games from those platforms (well you could on PS4 for DCUO, but obviously we don't need to go there) Oh except for SWTOR. I believe you can possibly buy time on Origin for that. though see the DCUO example above. Also you "technically" do pay more in plenty of cases. For example, Marvel Heroes has in-game cash tiers that are not offered on Steam. Likewise every time Marvel Heroes runs an IGC sale on their store, the sale isn't on Steam. It's really the only game I play that money is involved where you can pay from multiple places.. but I'm sure if I looked I could find additional pricing disparities where something was priced better directly from the developer than it was on Steam or such.

But can't you see that it's Apple's policies that caused this?
I never disputed that. The entire topic has been "is it anti-competitive and/or illegal". Of course their policy caused it, and it's their policy to enforce or not. And it's the devs choice to work with it or around it. And it's my choice to support the dev in their choice or not. I never disagree with any of that.

Just the part where people are saying Apple should be raked over coals by the government over it.

So no mmo lets you pay within the game or asks for a cc when you first setup the game? You have to go to the game's website first to create and account and pay?

Pretty much. FFXIV and ESO don't even use your PSN account in the slightest. I don't know of an MMO that you can sign up through Steam with. And my Marvel Heroes example above where they offer pricing, bundles, tiers and values from their web store that they don't offer on Steam. etc
 

KHarvey16

Member
Well people keep making the comparison. Windows isn't a walled eco system, but the Windows app store is. Same with the OSX store. What's also a walled garden is PSN and Xbox Live. People keep comparing them to these services, but if you want to make the comparison you have to look at how they all handle subscription services. None of them take a 30% cut because none of them force them to use their service for subscriptions. Apple is the only one who does.

You certainly don't have to sign up for a service through the AppStore. I don't think most services even let you do this if you wanted to.
 

S¡mon

Banned
Third party developers compete with first party developers in consoles the same way Apple competes with Spotify. Microsoft has Forza and third parties are also developing racing games. I can't see how you can differentiate those in any useful way in relation to the analogy.
I still feel like this isn't good comparison, but even so, there is no harm to consumers: both games have a recommended retail price of $59.

For Spotify, it is literally impossible to match Apple's $9.99 pricing as they are already making losses when Apple doesn't take a cut at all.

I am not saying that Apple can't ask any money for their services, to be available on their platform. But Apple has hundreds of millions of active users. For those users, there are two choices: go with Apple's service at $9.99 (Apple wins) or go with Spotify's service at $12.99 (Apple wins, Spotify loses (as in: can't price match) and the consumer loses (higher pricing)).

If Apple's cut was something like 1-5%, Spotify would likely be able to price match. In that scenario, there is no harm to consumers, there will be good competition and Apple still makes money to run the App Store and handle payments.
 

rezuth

Member
S¡mon;171579929 said:
I still feel like this isn't good comparison, but even so, there is no harm to consumers: both games have a recommended retail price of $59.

For Spotify, it is literally impossible to match Apple's $9.99 pricing as they are already making losses when Apple doesn't take a cut at all.

I am not saying that Apple can't ask any money for their services, to be available on their platform. But Apple has hundreds of millions of active users. For those users, there are two choices: go with Apple's service at $9.99 (Apple wins) or go with Spotify's service at $12.99 (Apple wins, Spotify loses (as in: can't price match) and the consumer loses (higher pricing)).

If Apple's cut was something like 1-5%, Spotify would likely be able to price match. In that scenario, there is no harm to consumers, there will be good competition and Apple still makes money to run the App Store and handle payments.

Why should Apple be punished because Spotify can't make deals good enough for them to survive on?
 

S¡mon

Banned
Why should Apple be punished because Spotify can't make deals good enough for them to survive on?

Apple is in a position of huge power. They demand a 30% cut and Apple actively rejects apps that suggest payment options other than that of an in-app purchase.
Or in other words: if you don't want to pay 30% of your revenue and point your customers to alternatives, you'll be actively blocked and kept away from hundreds of millions of potential buyers.

Spotify has basically three options:

- Don't offer in-app purchases and lose access to hundreds of millions of potential customers (bad for competition)
- Offer in-app purchases at $9.99 and take a huge loss (bad for competition and gives Apple even more power)
- Offer in-app purchases and slightly raise the price to $12.99 to cover the 30% cut (bad for consumers, because higher pricing and bad for competition, because Apple's own alternative becomes more attractive for consumers)

So the amount of competitors might become lower, the financial situation of competitors might worsen in favour of a company that already makes billions of dollars profit each month and/or the prices for consumers might rise. Apple always wins... consumers and competing companies always lose.

If you still feel like Apple is allowed to demand a 30% cut... that's fine, but I heavily disagree. In my opinion, Apple shouldn't be allowed to have that much power over the entire market.

You can disagree and feel like Apple should be allowed to become bigger and gain even more power. That's fine, different people have different opinions. But I, and apparently many others, believe that we have now reached a point where Apple has too much power.
 

Apt101

Member
Apple built a strong marketplace that put a lot of eyes on a lot of products. Consumers are relying less on walled gardens and going directly to the source in many cases (even for things like television). So I guess this is a smart move. I can't see it hurting them, so why not go for it?
 
Spotify has always had a free tier, 2013 was the launch of it on mobile as well as desktop. The following year saw France and UK turn a profit:

http://billboard.com/articles/business/6320047/spotify-france-profit-2013

France had a 76% jump in premium subscribers.
No. In 2011 Spotify limited their free tier to 2.5 hours per week and 5 plays per track that never reset. The free version was utterly useless and you had to pay. They had a half price "remove ads and limits" option though.
 

slit

Member
Do you buy digital games? Its the same, you have to pay 30% there, to! Doesnt matter if its Steam, PSN, Nintendo eStore or Xbox Live, its everywhere!
Google also wants 30%.
And its ok, why the fuck should the companys give their servers and exposure away for free?

Inform youself before you write bullshit in the internet.

Great, I'll inform myself for making a tongue-in-cheek comment while you get psychological help for flying off the handle for criticizing Apple.

How silly and shallow.
 
S¡mon;171582461 said:
Apple is in a position of huge power. They demand a 30% cut and Apple actively rejects apps that suggest payment options other than that of an in-app purchase.
Or in other words: if you don't want to pay 30% of your revenue and point your customers to alternatives, you'll be actively blocked and kept away from hundreds of millions of potential buyers.

Spotify has basically three options:

- Don't offer in-app purchases and lose access to hundreds of millions of potential customers (bad for competition)
- Offer in-app purchases at $9.99 and take a huge loss (bad for competition and gives Apple even more power)
- Offer in-app purchases and slightly raise the price to $12.99 to cover the 30% cut (bad for consumers, because higher pricing and bad for competition, because Apple's own alternative becomes more attractive for consumers)

So the amount of competitors might become lower, the financial situation of competitors might worsen in favour of a company that already makes billions of dollars profit each month and/or the prices for consumers might rise. Apple always wins... consumers and competing companies always lose.

If you still feel like Apple is allowed to demand a 30% cut... that's fine, but I heavily disagree. In my opinion, Apple shouldn't be allowed to have that much power over the entire market.

You can disagree and feel like Apple should be allowed to become bigger and gain even more power. That's fine, different people have different opinions. But I, and apparently many others, believe that we have now reached a point where Apple has too much power.

The entire market is apple devices? You want a free lunch?
 

borghe

Loves the Greater Toronto Area
FTC Looking Into App Store Rules Regarding Subscription Services
http://www.macrumors.com/2015/07/11/ftc-app-store-rules/
Nothing will come of it. The FTC seemingly "looks into" everything nowadays. The only way something comes of it is if there is something off the records or unknown of here. If the DOJ didn't fine Apple for the Kindle mess (which would have actually been a bit deserved), they're certainly not going to fine them for standard markups and costs of doing business. I mean it's not like they can force Apple to lower/waive what's essentially a transaction fee for facilitating a sale, or artificially raise their price on their own service. Especially when there are a number of already existing alternative options and services.
 

KHarvey16

Member
S¡mon;171579929 said:
I still feel like this isn't good comparison, but even so, there is no harm to consumers: both games have a recommended retail price of $59.

But first party games don't lose money to license fees. It's the same as Spotify not passing the fee on to consumers and eating it.

S¡mon;171579929 said:
For those users, there are two choices: go with Apple's service at $9.99 (Apple wins) or go with Spotify's service at $12.99 (Apple wins, Spotify loses (as in: can't price match) and the consumer loses (higher pricing)).

That's not correct. People with Apple devices can still buy Spotify subscriptions for $9.99. This thread is literally about doing that.
 

S¡mon

Banned
That's not correct. People with Apple devices can still buy Spotify subscriptions for $9.99. This thread is literally about doing that.
You are forgetting that Spotify isn't allowed to mention it in their app... at all. They also can't use their own payment system and linking to their website is forbidden.

For many consumers, there IS only one option: the $12.99 plan, as they are unaware of a cheaper plan being available on Spotify's website.
 

KHarvey16

Member
S¡mon;171659998 said:
You are forgetting that Spotify isn't allowed to mention it in their app... at all. They also can't use their own payment system and linking to their website is forbidden.

For many consumers, there IS only one option: the $12.99 plan, as they are unaware of a cheaper plan being available on Spotify's website.

Again, this thread is specifically about Spotify notifying their customers of the cheaper way to sign up. They could have done this at any time, but strangely waited until Apple had released a competing product.

Edit
And don't forget they could simply not offer the ability to sign up through the App Store, like almost all other subscription based apps. Somehow they manage.
 

chris121580

Member
I just got an email that they now send me a playlist every Monday of songs they think I'll like based on what I listen to. It's about 2 hours long. I think that's pretty damn cool of them
 
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