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Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →Outbyte PC Repair FREERepair Windows errors before they cause bigger problemsFix Now →A Tokyo District Court has said a person’s voice can qualify for protection under publicity rights when it has customer-attracting power and its unauthorized use is aimed exclusively at exploiting that appeal. But the court did not decide whether the disputed TikTok narration was Kenjiro Tsuda’s voice, or whether TikTok was liable: it dismissed his request to remove the videos because they had already been deleted.
What did the Tokyo court decide?
In a judgment delivered on 30 September 2026, the Tokyo District Court set out a conditional basis for protecting a person’s voice under publicity rights. It said a human voice, like a portrait, can symbolize an individual’s personality; where the voice has customer-attracting power, unauthorized use may infringe publicity rights if it is aimed exclusively at taking advantage of that appeal. The judgment is the primary source for the court’s reasoning.
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This is not a blanket ban on AI-generated voices, imitation, or every use of a recognizable voice. The principle described by the court is conditional, and the ruling is from the Tokyo District Court. The available sources do not establish that it has been reviewed on appeal.
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The case, Tokyo District Court matter 令和7(ワ)70635, was brought by voice actor, actor, and narrator Kenjiro Tsuda against TikTok Pte. Ltd. Tsuda sought removal of videos posted by an anonymous account. The judgment says the account published 188 videos between July 2024 and September 2025, combining footage and subtitles with narration about urban legends, paranormal phenomena, and trivia. It had more than 210,000 followers as of November 2025.
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Tsuda argued that the narration sounded like his distinctive voice and used its audience appeal to attract viewers and generate revenue. The judgment records his reliance on listener comments and an audio-comparison analysis. Those were Tsuda’s submissions, not findings the court adopted.
TikTok disputed that the narration was Tsuda’s voice or sufficiently similar. It argued that the voice was an AI-processed third party’s voice, and contested confusion, commercial exploitation, and whether the platform had a duty to remove the posts. The court did not resolve those disputed questions.
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Why did the court dismiss the removal request?
The account owner deleted the account on 29 May 2026 and did not seek its restoration within 30 days. The court found that the account data, including the posts at issue, had been deleted from TikTok’s servers after 28 June 2026. By the close of oral argument, there was no material left for TikTok to remove. The court therefore dismissed the deletion claims, reasoning that even if a removal obligation could have arisen, the material had already been deleted.
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So the court did not order TikTok to take the videos down, and the dismissal was not a finding that TikTok had acted lawfully on the merits. The judgment expressly left the remaining disputed issues undecided.
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How the legal claims differ
Tsuda’s complaint relied on two legal routes: Japan’s Unfair Competition Prevention Act and publicity rights. They should not be conflated with copyright; the case proceeded on those two theories, not a copyright claim.
Publicity rights
The court’s voice-related reasoning concerns commercial appeal: whether a voice has customer-attracting power and whether its unauthorized use is aimed exclusively at exploiting that appeal. It articulated that conditional principle without deciding whether the disputed narration met the test.
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Unfair competition
Tsuda also invoked the Unfair Competition Prevention Act. Because the posts were already gone, the court did not proceed to decide the remaining contested issues, including the dispute over the particular narration and the platform’s responsibility.
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The judgment matters because it expressly treats a human voice as potentially significant to a person’s commercial identity, rather than limiting publicity-rights reasoning to a person’s portrait. The Associated Press reported the presiding judge, Aya Takahashi, as saying: “The human voice is symbolic of individual personality, just like one’s portrait.” The Associated Press report provides accessible English context.
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For creators, platforms, and people concerned about synthetic voice use, the practical point is limited but important: a voice’s commercial appeal may support a publicity-rights claim under the conditions the court described. This case does not settle whether a particular imitation is close enough, whether a use is exclusively exploiting that appeal, or what remedy would follow. Those questions were not decided here.
The Ministry of Justice has also announced a study-group report addressing civil liability for unauthorized use of portraits and voices, including publicity rights, personality interests, remedies, and unfair competition. The ministry announcement establishes the report’s subject, but does not itself resolve how the Tsuda case’s remaining issues should be answered.
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