Tokyo District Court recognizes voice as protected by publicity rights in AI-clone case, dismisses takedown as moot

What happened

The Tokyo District Court on September 30, 2026 ruled that a human voice is subject to publicity rights, in a case brought by anime voice actor Kenjiro Tsuda over AI-generated narrations imitating his voice posted on TikTok. It is the first time a Japanese court has made such a judgment.

Details

• Tsuda sued the social media platform operator in November 2025. According to the complaint, 188 videos narrated by a voice imitating Tsuda's were posted from a specific account between July 2024 and September 2025. The account had about 210,000 subscribers and averaged roughly 1.47 million views per video, earning the creator between 500,000 and 750,000 yen per month.
• Presiding Judge Aya Takahashi ruled: "Human voice is a symbol of an individual's personality, just like image," and said unauthorized use of voice could constitute an infringement of rights. The plaintiff's team concluded from voice-data analysis that Tsuda's distinctive voice had been intentionally created by generative AI.
• The takedown demand was dismissed because the videos had already been deleted. The operator had argued the person who posted the videos had generative AI learn a friend's voice, amounting to no more than a generic male voice.
• Separately, a Justice Ministry expert panel released guidelines in August stating that voices, like images, should be protected under publicity rights.

Boundary

The court recognized the right but dismissed this demand as moot, so the case did not produce an order against the operator.