Tsuda v TikTok Pte Ltd
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In Tsuda v. TikTok Pte. Ltd., Japanese voice actor Kenjiro Tsuda sought removal of 188 TikTok posts that he said used an AI-generated voice resembling his own. The Tokyo District Court dismissed the removal claims on September 30, 2026, after finding that the account and its posts had already been deleted. Its judgment stated that a performer's voice may be protected by publicity rights under specified commercial-use conditions, while leaving infringement in this case undecided.[1]
Background and claims
The court recorded that an unidentified user posted 188 videos between July 2024 and September 2025. Tsuda alleged that their narration resembled his voice and sought removal from TikTok Pte. Ltd. under Japan's Unfair Competition Prevention Act and publicity-rights principles. TikTok disputed the alleged similarity and argued that the account had already been deleted.[1]
September 30 judgment
The court said a person's voice, like a portrait, can symbolize personality. Unauthorized use of a performer's voice can infringe a publicity right when the voice has customer-attracting commercial value and the use is solely to exploit that value. The court did not decide whether the challenged narration met those conditions.[1]
The court found that the account holder deleted the account on May 29, 2026, and that its data, including the challenged posts, was removed from TikTok's servers after June 28. It therefore rejected all requested removal relief and ordered Tsuda to bear litigation costs. It did not decide the remaining unfair-competition and publicity-rights issues.[1]