The line the court drew

In Kenjiro Tsuda's case, the Tokyo District Court said a performer's voice can be protected by the publicity right. Its reason was the voice's ability to draw an audience or customers. Under the general rule the court described, unauthorized imitation specifically exploiting that commercial appeal can infringe the right. For a performer whose voice is part of the work, the consequential point is that protection is not confined to a face or photograph.[1]

Tsuda had asked for a different, practical outcome: an order requiring TikTok to remove the videos. The posting account was deleted while the case was pending, so the court dismissed that request. The dismissal does not erase the court's statement about voice rights. These parts of the decision answer different questions. Tsuda's lawyer said deletion of the account had already achieved the plaintiff's original objective.[1]

From claimed similarity to a remedy

The contested material was a set of AI videos from an anonymous account with narration alleged to resemble Tsuda's voice. His lawyer said the plaintiff compared the voices with several deep-learning methods and submitted the code used for that comparison. This describes an evidentiary route, but the report does not say the court treated a particular similarity score as proof of origin. Recognizing a voice's commercial value does not establish that every similar voice was generated from that performer.[1]

A separate obstacle arose in identifying the poster. Tsuda's side sought account information, but the relevant internet-address logs had expired before the person could be identified. The account owner later deleted the videos. The concrete difficulty in this case is that voice similarity, the poster's identity, and the available remedy require different evidence. Establishing one does not automatically settle the others.[1]

What the decision leaves open

The ruling explains that a voice can receive protection, while this case ended without a removal order for videos already gone. In another dispute, the evidence would still need to address whose voice is involved, the purpose of the imitation, and whether the content remains accessible. Tsuda did not seek damages, and his lawyer said there was no plan to appeal. This case supplies no award of money and no decision imposing a new monitoring duty on the platform.[1]