BODY: A voice actor lost his case and won the argument that mattered.
On September 30, the Tokyo District Court dismissed Tsuda Kenjiro's lawsuit demanding that TikTok's operator delete videos that used generative AI to clone his voice. The reason was procedural rather than substantive: the account had already been taken down around May, so there was nothing left to order removed.
Buried in the dismissal is the part Japanese entertainment lawyers will be citing for years. The court held that a voice can be the subject of publicity rights — the judge-made doctrine, cemented by the Supreme Court's 2012 Pink Lady ruling, that protects the commercial pull of a celebrity's identity. Until now that doctrine has been understood to cover names and likenesses. The court found that where a voice carries "customer attraction power" and is used without permission primarily to exploit that pull, the use is infringing. Tsuda's attorney called it the first judgment to state explicitly that voice sits inside the scope of publicity rights.
The underlying account was not a fan tribute. Opened in July 2024, it narrated urban legends in a synthetic approximation of Tsuda — the gravelly baritone familiar to anime audiences as Kento Nanami in Jujutsu Kaisen and to Japanese TV viewers from countless narration gigs. It reached 100,000 followers and was reportedly earning roughly ¥700,000 a month by January 2025.
The finding also aligns with a government study report from August 2025 that reached a similar conclusion, suggesting the judiciary and the bureaucracy are converging on the same answer.
The insider take
Japan has no statute creating publicity rights at all — the entire doctrine is scaffolding built by courts, which is exactly why a single district court paragraph carries this much weight. The seiyuu industry has been lobbying hard since the 2024 "NOMORE 無断生成AI" campaign, in which prominent voice actors warned that unauthorized AI training and cloning threatened an occupation Japan essentially invented as a career path. Agencies here have long argued that a voice actor's instrument is the product, in a way that a screen actor's face is not. That argument now has a citation. Expect the next plaintiff to sue before the account gets deleted.
Originally reported by はてなブックマーク (Japanese).