Tokyo court puts voice inside publicity rights, and still dismisses Tsuda's order

The Tokyo District Court ruled on 30 September that a human voice can be protected as a publicity right, the first time a Japanese court has said so. Presiding Judge Aya Takahashi dismissed the order that voice actor Kenjiro Tsuda had asked for, because the TikTok videos were already gone. The principle stands without the injunction. Tsuda left with a precedent his guild can cite, and without a deletion order the platform had already carried out.

Tsuda, known for leading roles in series including Jujutsu Kaisen, sued TikTok's operator in November 2025. He said 188 videos on one account, posted between July 2024 and September 2025, were narrated by an artificial clone of his voice. He asked the court to order them removed, relying on publicity rights and the Unfair Competition Prevention Act. Publicity rights, in Japanese case law, let a person control commercial use of identity markers such as a name or a face. The open question was whether a voice counted.

What Takahashi held

The ruling said a human voice is a symbol of personality, just as an image is, and that unauthorised use can infringe rights. Takahashi applied that holding to the category, not to a finding that these 188 videos were in fact his voice. The court did not decide whether the synthetic narration copied him. TikTok had argued that the account holder let a generative system learn a friend's voice, and that the result was a generic male voice. That defence was not ruled on, because the remedy Tsuda wanted was no longer available.

The account had been deleted before judgment. A court that is asked only to order removal cannot order removal of files that are gone. Dismissal on that ground is ordinary. What is not ordinary is the paragraph on the right. The Japan Times and later explainers on 2 October both treated that paragraph as the operative result. It is the first Japanese judgment to place voice inside publicity rights.

Why the remedy and the rule split

Tsuda's commercial problem was the 188 videos. His professional problem was the absence of a sentence he could show a platform. The videos ended when the account ended. The sentence exists because he sued anyway. Japanese voice actors now have a district-court holding that unauthorised commercial use of a voice can be an infringement, in the same family as unauthorised use of a face. A district-court judgment does not bind every later court. It is the authority the next plaintiff will attach to a filing, and the authority a platform lawyer will have to answer.

The case did not decide consent, training data, or whether a model that has learned a voice from public performances is a copy. Those questions sit underneath every AI-voice dispute. Takahashi did not reach them. She reached the prior question, which is whether the law has a hook at all. The answer, in this court, is yes.

What the guild can do with one paragraph

A deletion order would have bound TikTok on this account. A holding on the right binds no one until the next case, and then only as persuasion. The practical use is earlier, in the letter before action. A lawyer for a voice actor can now quote a named judge, a date, and a comparison to portrait rights. Before 30 September that letter cited articles and industry statements. The difference is the difference between a claim and a claim with a judgment under it.

Tsuda's own file is closed on the videos and open on the principle. Both sides can describe a win, which is why the 2 October coverage treated the outcome as split. TikTok does not have to restore anything or take anything down. Tsuda does not have a damages figure in the reports of the judgment. The sentence about personality is the part that will be copied into the next complaint, in Tokyo or in another district, the next time an account narrates a show in a voice the actor says is his.