United States · Personality Rights and Right of Publicity

US Lovo Voice Cloning Case

Two voice actors alleged that their voice recordings were used without authorization to develop and commercialize AI voice clones. The court allowed claims for breach of contract, commercial misappropriation of personality under New York law, and consumer protection to proceed, while treating training-stage copies, underlying audio recordings, and synthetic outputs under separate legal frameworks.

Court or tribunal
U.S. District Court for the Southern District of New York
Decision date
9 July 2025
Procedural status
Order on Motion to Dismiss in Part; Proceedings Stayed due to Bankruptcy
Case number
No. 24-cv-03770-JPO

01

Factual background & dispute

  • The voice actors accepted limited-scope recording assignments through a freelance platform.
  • The plaintiffs subsequently discovered that synthetic voices closely mimicking their own were marketed in AI voiceover products.
  • The complaint asserted claims under copyright, trademark, contract, right of publicity, and consumer protection laws.

02

Core issues & judicial focus

  1. Which distinct legal protections apply to a voice itself, the sound recordings, and synthetic voice clones
  2. Whether a limited-use voice assignment extends to AI model training and commercial voice synthesis products
  3. How training-stage copying and synthetic model outputs should be evaluated separately

03

Judicial finding & holding

  • The court allowed certain claims for sound recording copyright infringement, breach of contract, New York statutory right of publicity, and deceptive trade practices to proceed.
  • The court dismissed certain copyright and trademark claims regarding model training and outputs, granting leave to amend the training-related copyright claims.
  • The proceedings were stayed following the defendant's bankruptcy filing, leaving substantive liability unresolved.

04

Practical risk implications

01Voice licensing agreements should delineate distinct provisions for master recordings, vocal characteristics, AI training rights, and synthetic outputs.

02AI voice vendors must maintain provenance records and licensing documentation for source recordings and derivative voice models.

03Downstream procurers should secure clear sublicensing scope, representations on personality rights, and commitments for ongoing takedown support.

Court documentsFull judgments and orders1 document

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