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Tokyo court recognizes publicity rights may cover human voices

3 OCTOBER 2026·2 MIN READ·4 SOURCES

The Tokyo District Court ruled on Sept. 30 that human voices can fall under publicity rights, marking the first time a Japanese court recognized legal protection for a person’s voice. The court said unauthorized use may infringe those rights under specific conditions, but it did not decide whether the videos at issue violated voice actor Tsuda’s rights.

Tokyo court recognizes publicity rights may cover human voices

Key takeaways · 4

  • 01

    The ruling recognizes that a voice can receive publicity-rights protection in Japan, but does not make every AI-generated voice imitation an infringement.

  • 02

    The court’s stated test concerns a voice with customer-attracting power used solely to exploit that appeal.

  • 03

    The court did not decide whether Tsuda’s rights were infringed, because the videos had already been removed.

  • 04

    The case involved 188 videos, and the court found TikTok’s operator had no obligation to remove them.

A conditional standard for voice use

The court likened a person’s voice to their appearance, describing both as symbols of personality.[2] It said unauthorized use of a performer’s voice may infringe publicity rights when the voice has customer-attracting power and is used solely to exploit that appeal.[1] That formulation makes the commercial purpose and appeal of a voice relevant to the analysis; the ruling does not say that resemblance alone establishes infringement. Japan has no statute that explicitly defines a right to one’s voice.[1]

What the lawsuit concerned

Tsuda sought the removal of TikTok videos, arguing that generative AI had imitated his voice without authorization.[1] The lawsuit concerned 188 videos posted between July 2024 and September 2025, with narration resembling his voice.[1] When the suit was filed, the account had more than 210,000 followers, and its videos averaged roughly 1.47 million views each.[1][3] The account’s creator was reported to earn between ¥500,000 and ¥750,000 a month from the videos.[3] Tsuda is best known for voicing Kento Nanami in “Jujutsu Kaisen.”[2]

The court did not rule on infringement

The videos had already been removed, so the court did not decide whether Tsuda’s publicity right had been infringed.[1] It also dismissed his demand that TikTok remove them, finding that the platform operator had no obligation to take them down.[1] Tsuda’s attorney said the plaintiff would not appeal and that the arguments had been recognized in substance.[1] TikTok’s operating company said it would continue seeking a balance between technological advancement and rights protection.[1] The ruling therefore establishes a legal principle without resolving the central infringement question in this case.[1]

A developing area of protection

Japan’s Supreme Court first recognized publicity rights as legally protected in 2012, while the Tokyo ruling was the first time a Japanese court recognized legal protection for a person’s voice.[1] A Justice Ministry expert panel said in August that voices, like images, should be protected under publicity rights.[3] Copyright law does not protect a celebrity’s actual voice or its vocal qualities.[1] Tsuda’s legal team said its analysis found that generative AI intentionally produced a voice resembling his distinctive voice.[3] The ruling could make it easier to seek damages or injunctions for unauthorized voice use.[1]

For teams using synthetic narration, the decision makes voice rights a legal issue to assess alongside the content and purpose of a production. The court’s conditional standard and its decision not to rule on infringement leave important questions for future disputes.

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How this developed

  1. 3 October 2026

    Tokyo court recognizes publicity rights may cover human voices

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