Tokyo court recognizes publicity rights may cover human voices
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.

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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3 October 2026
Tokyo court recognizes publicity rights may cover human voices
Sources
- Landmark ruling backs protection of human voices in AI cloning age | The Asahi Shimbun: Breaking News, Japan News and Analysisasahi.com
- Japan court rules voice is protected as publicity right in AI cloning caseenglish.kyodonews.net
- While calling voice a protected right, court dismisses voice actor’s AI case - The Japan Timesjapantimes.co.jp
- Tokyo court grants legal protection to human voices in AI clone caseisp.netscape.com