Tokyo court recognises voice as a protectable publicity right in actor’s suit against TikTok account

# What the court decided

On September 30, 2026, the Tokyo District Court ruled that a person's voice can be covered by publicity rights when it is used specifically to exploit commercial appeal. Presiding Judge Aya Takahashi described a voice as a symbol of personality comparable to a likeness or portrait.

The judgment did not find, however, that the plaintiff's rights had definitively been violated. The court also dismissed the plaintiff's request to have the contested videos removed because the anonymous account that posted them had already been deleted in May 2026.

# Background: why the case was filed

Actor and voice artist Kenjiro Tsuda brought the lawsuit in November 2025. He said an anonymous TikTok account published 188 videos between July 2024 and September 2025 that used a voice he says imitated his distinctive baritone. The videos narrated content about urban legends, the occult and conspiracy theories and the account drew over 200,000 followers.

Tsuda's legal team estimated the account could have generated ¥500,000 to ¥750,000 per month in view-based creator payouts. TikTok countered that the videos used a generic male voice, that any resemblance was subjective, and that the account holder claimed to have trained the voice model on a friend's voice.

# Why this matters for performers and content platforms

The ruling matters because it recognises vocal identity as a commercial attribute that can be protected under existing publicity rights law. That gives performers a legal basis to challenge uses of voice likenesses intended to attract viewers or revenue.

At the same time, because the court did not determine actual infringement in this case and did not award damages or order removals, it leaves numerous practical questions open. Those include how to prove a voice was copied, how much similarity is required, and what remedies are appropriate when platforms host or host-removed content.

# How this fits with recent policy and legal developments

This decision arrives as Japan and other jurisdictions work to apply current legal frameworks to new voice-cloning technologies. In August, a Justice Ministry expert committee in Japan published guidance acknowledging that voices can be protected alongside likenesses, highlighting unauthorized cover songs that use singers' voices.

# What the ruling did and didn't do

• It established the legal principle that a voice can be a publicity right when used for its commercial appeal.
• It did not find on the facts that Tsuda's rights were infringed.
• It denied the removal request because the contested TikTok account had already been deleted.
• Tsuda did not seek damages in this action.

# Practical implications for performers and platforms

Performers now have a clearer argument in Japan for seeking legal protection against unauthorized use of their vocal identity. Platforms and creators who use synthesized or cloned voices should anticipate heightened scrutiny and clearer legal challenges. Legal outcomes in future cases will depend on how courts apply the newly articulated principle to specific factual records of similarity, intention, and commercial exploitation.