Facts
Between July 2024 and September 2025 an anonymous TikTok account posted 188 videos on urban legends, the occult and trivia, narrated in a voice resembling that of voice actor Kenjiro Tsuda. By November 2025 the account had more than 210,000 followers. A site linked from the account stated that the narration was not Tsuda's voice but came from AI trained on the voice of a friend who imitated him well. In November 2025 Tsuda sued TikTok Pte. Ltd., the Singapore company operating the platform, in the Tokyo District Court, seeking deletion of the videos under his right of publicity and the Unfair Competition Prevention Act. The poster deleted the account on 29 May 2026.
What was the legal question in Kenjiro Tsuda v. TikTok Pte. Ltd. (投稿記事削除請求事件)?
Japanese law has no statute expressly protecting a person's voice, and a voice is not a copyright work. The court had to decide whether the right of publicity, which Japanese courts had recognised for names and likenesses, can extend to a voice, and if so on what test. The operator argued that the narration was a 'generic male voice' with no risk of confusion. It also argued that, as the videos had already been deleted, the claimant had no remaining interest and the claim should be dismissed as inadmissible. The claimant replied that closing the account did not show the data had actually been erased.
What did the Tokyo District Court, 46th Civil Division decide?
The court (presiding judge Aya Takahashi) stated as a general principle that a voice, like a likeness, is a symbol of individual personality and can be protected by the right of publicity. Using a performer's voice without permission infringes that right where the voice attracts customers and the use aims exclusively at exploiting that attraction, the test the Supreme Court of Japan set for names and likenesses in the 2012 Pink Lady case. Whether anything remained to delete was a question of merits, not admissibility. The court found that the data left the operator's servers at the end of 28 June 2026 and, with nothing left to remove, dismissed the claim without ruling on infringement or unfair competition.
Why does Kenjiro Tsuda v. TikTok Pte. Ltd. (投稿記事削除請求事件) matter?
It is reported as the first Japanese decision recognising that a voice can be protected by the right of publicity. The statement on voice did not decide the outcome, which turned on deletion, and the court made no finding on the videos or on how close an AI imitation must be to infringe. It came shortly after a Ministry of Justice study group said, in an August 2026 report, that voices may be protected by publicity rights. No damages or unjust enrichment were claimed, so the ¥500,000 to ¥750,000 a month the claimant said the poster earned was not examined.
Related stages
Other voice actors noted that, despite the dismissal, the original aim of getting the posts removed had been achieved, and the Japan Actors Union (日本俳優連合) said it would comment after reading the full judgment. The full text has been published in the courts' case-law database. As of 1 November 2026 no appeal had been reported; the two-week appeal period, which runs from service of the judgment, would be expected to have ended, but the service date is unknown and finality could not be confirmed officially.