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A Tokyo District Court ruling says a person’s voice can qualify for publicity-rights protection when it has customer-attracting power and its unauthorized use is aimed exclusively at exploiting that appeal. The court did not order TikTok to remove videos allegedly using voice actor Kenjiro Tsuda’s voice: the posts had already been deleted, so the court dismissed the removal request without deciding the remaining disputed issues.
What the Tokyo court decided
In case 令和7(ワ)70635, titled 投稿記事削除請求事件, the Tokyo District Court issued its judgment on 30 September 2026. It articulated a conditional principle: a human voice can be a symbol of individual personality, and unauthorized use may infringe publicity rights if the voice has customer-attracting power and the use is aimed exclusively at exploiting that appeal. Read the Tokyo District Court judgment.
That principle is not a blanket prohibition on AI-generated voices, voice imitation, or all noncommercial uses. It describes a possible basis for publicity-rights protection; whether the conditions apply depends on the particular use and facts.
Why the court dismissed the request against TikTok
Tsuda, a voice actor, actor, and narrator, asked TikTok Pte. Ltd. to remove videos from an anonymous account. The account owner deleted the account on 29 May 2026 and did not seek restoration within 30 days. The judgment found that the account data, including the posts at issue, had been deleted from TikTok’s servers after 28 June 2026.
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Because the material was already gone by the close of oral argument, the court concluded that TikTok had deleted it even if a deletion obligation could have arisen. It dismissed the removal claims. It did not order TikTok to take down the videos, find the platform liable, or decide the remaining disputed issues.
What the dispute involved
The judgment describes 188 videos posted between July 2024 and September 2025. They combined footage and subtitles with narration about urban legends, paranormal phenomena, and trivia. The account had more than 210,000 followers as of November 2025. Those figures describe this case, not the prevalence of AI voice cloning.
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Tsuda argued that the narration resembled his distinctive voice, which he said functioned as a business identifier, and that it used the audience appeal of his voice to attract viewers and revenue. His submissions included listener comments and an audio comparison analysis. These were his arguments as recorded in the judgment, not findings the court adopted.
TikTok disputed that the voice was Tsuda’s or sufficiently similar. It argued that the narration was an AI-processed third party’s voice, and contested confusion, commercial exploitation, and any duty on the platform to remove the posts. The court did not resolve those contested points.
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The two legal theories are different
Publicity rights
The court’s voice-related reasoning concerns publicity rights: protection against unauthorized use of a person’s identity or attributes to exploit their commercial appeal. For voices, the judgment’s stated conditions are that the voice has customer-attracting power and that the unauthorized use is aimed exclusively at exploiting that appeal. The court did not determine whether Tsuda’s voice met those conditions in this particular dispute.
Unfair competition
Tsuda also relied on Japan’s Unfair Competition Prevention Act. That was a separate legal route from publicity rights. The court’s dismissal based on the posts’ prior deletion meant it did not decide the remaining issues, including the disputed unfair-competition questions. The case is not a ruling that publicity rights and copyright are interchangeable.
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What the ruling means—and what it does not
Presiding Judge Aya Takahashi was quoted by The Associated Press as saying, “The human voice is symbolic of individual personality, just like one’s portrait.” Associated Press coverage. The quote captures the court’s recognition that a voice can have personal significance; it should not be read as a finding that every imitation infringes a right.
- It establishes: the Tokyo District Court articulated a conditional basis for protecting a voice’s commercial appeal through publicity rights.
- It does not establish: that the disputed narration was in fact Tsuda’s voice, that TikTok was liable, or that the court found the particular use unlawful.
- It does not establish: a blanket ban on AI voice cloning or a final nationwide rule. The judgment is from a district court, and the available sources do not establish appellate review.
Japan’s Ministry of Justice has announced a study-group report on civil liability for unauthorized use of portraits and voices, including publicity rights, personality interests, remedies, and unfair competition. The announcement confirms the report’s scope but does not, by itself, settle how the issues in Tsuda’s case should be resolved. Ministry of Justice announcement.
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