Why Japan’s AI voice ruling produced no TikTok takedown order

An actor’s familiar voice can draw attention to words they never agreed to say. That is the cultural stake in Kenjiro Tsuda’s lawsuit against TikTok over videos he alleged used an unauthorized AI imitation of his voice. Tsuda, whose roles include Kento Nanami in Jujutsu Kaisen, sought to have the videos removed. Fuji Television

On September 30, the Tokyo District Court recognized that voices can fall within the protection of publicity rights, much as a person’s likeness can. Yet it dismissed Tsuda’s removal request because the account publishing the disputed material had already been deleted, Fuji reported. Recognition of protection and dismissal of the claim were two distinct parts of the outcome. Fuji Television

The result becomes clearer when three questions are kept apart: can a voice receive protection, what makes a particular use infringing, and what remains for a court to order removed?

Publicity rights concern the commercial appeal of someone’s identity—the ability of a recognizable name, face or other identifying feature to attract customers. According to AFP’s account of the ruling, the court treated a voice as an expression of personality comparable to a portrait. That gives performers a legal basis for arguing that their recognizable sound has value someone else cannot freely exploit. AFP via CNA

For voice actors, that sound also represents work. Yuko Sasaki, executive director of the Japan Actors Union, told AFP before the ruling that performers develop their voices through years of training and apprenticeship, investing time and money in the process. AFP via CNA

The second question concerns how someone uses that identity. Bengo4’s follow-up describes the court’s reasoning as a general principle: unauthorized use can infringe when a voice has commercial drawing power and is used exclusively to exploit that appeal. The Japanese expression 顧客吸引力 means the power to attract customers. This condition makes the purpose of the use central to the reported reasoning. Bengo4, syndicated by Livedoor

The disputed account paired narration about urban legends and other subjects with an image resembling a character Tsuda voiced. His legal team argued that his vocal appeal attracted its audience. TikTok disputed the identification, describing the narration as a “generic male voice” and the perceived resemblance as subjective, AFP reported. Those remain competing claims. AFP via CNA

Recognizing that voices can receive protection does not, by itself, establish that these particular videos infringed Tsuda’s rights. Bengo4’s description of the reasoning as general is therefore significant: the principle helps identify what future claimants could argue, while proving a particular claim remains a separate task. Bengo4, syndicated by Livedoor

The Ministry of Justice’s work provides useful context. On August 7, it announced an interpretive report on unauthorized uses of likenesses and voices, following five study-group meetings examining hypothetical cases. Its stated remit was to clarify the application of existing law and judicial doctrine. The group considered infringement, compensation and the availability of orders stopping a use as separate legal issues. The publication was guidance on existing rights, rather than newly enacted legislation. Ministry of Justice

That leaves the third question: what could a removal order accomplish? Tsuda’s lawyer, Takashi Hirano, told Bengo4 that the uploader voluntarily deleted the account around May 2026, while proceedings were continuing. By judgment day, the material targeted by the request was gone. Hirano said that deletion had achieved his client’s original objective. Bengo4, syndicated by Livedoor

Bengo4 also reports that Tsuda never sought damages and that his side does not plan to appeal. A reported intention not to appeal does not establish that the judgment is legally final. For this case, however, the practical outcome was concrete: the account and videos had been removed, without a court order requiring TikTok to delete them. Bengo4, syndicated by Livedoor