Tokyo District Court Recognises Voice as Protected by the Right of Publicity in Voice Actor Kenjiro Tsuda's AI Clone Case, but Dismisses the Deletion Claims

On 30 September 2026 the Tokyo District Court ruled in the case brought by voice actor Kenjiro Tsuda against the operator of TikTok, recognising that a person's voice can be protected by the right of publicity. The court said that the human voice, like a portrait, is a symbol of individual personality, and that the unauthorised use of a performer's voice may infringe the right of publicity where the voice has the commercial appeal to promote sales and the use aims exclusively at exploiting that appeal. According to the Associated Press, this was the first acknowledgement of such a right to one's voice in Japan.
The case arose from a TikTok account called Nanami that used an AI voice resembling Tsuda's in more than 180 videos about urban legends and paranormal phenomena; Tsuda argued that the account profited by attracting viewers with his voice and sought deletion of the videos under the Unfair Competition Prevention Act or the right of publicity. The defendant argued that the videos used an AI-generated voice that sounded like his but was not his.
The limits of the ruling must be kept in view: the court dismissed all of the plaintiff's claims because the poster had deleted the account in May 2026 and no videos remained to be removed when the oral proceedings closed, and it did not decide whether the AI voice resembled the plaintiff's, whether individual videos infringed, whether the Unfair Competition Prevention Act was breached, or whether the platform had a duty to delete.
What the case establishes is a general rule that the voice is protected by the right of publicity, concerning the voice as a marker of personality and its commercial value; it should not be reported as Japan recognising copyright in voices, nor summarised as a win for the plaintiff.
Whether generating a similar voice with AI, without editing the original recordings, avoids the need for authorisation was not answered directly, but the general rule gives a basis for future disputes.
J&C recommends that businesses producing short-video narration, AI cover songs, digital endorsers and audio content obtain written authorisation before using an AI voice resembling a particular voice actor or public figure, with the scope, platforms and term of use set out in the contract; rights holders who find a suspected voice clone should secure evidence early, including the account, videos, views and revenue, because in this case the deletion claim lost its object once the account was closed.
Source: www.wral.com | pax.law | www.bengo4.com


