Two professional voice actors based sued Lovo, a company that sells AI-generated voiceover software alleging, among other things, copyright infringement. Plaintiffs claimed that defendant took their voices without permission and used them to create digital clones. Those clones were sold to customers under the pseudonyms “Kyle Snow” and “Sally Coleman.” Defendant moved to dismiss the copyright claims. The court provided a mixed ruling.
How it started
Plaintiffs asserted that defendant first contacted them on the freelance platform Fiverr in 2019 and 2020. Defendant’s representatives allegedly assured plaintiffs the recordings would only be used for private research, not public or commercial projects. Based on those promises, plaintiffs delivered the recordings. Each was paid a few hundred dollars.
Several years later, plaintiffs discovered their voices had been cloned. In 2023, they heard a podcast produced using Lovo’s software. Plaintiff Lehrman’s friends and colleagues said the cloned voice sounded exactly like him. After further research, plaintiffs learned that defendant had built digital voice profiles from their recordings and offered those profiles to customers as part of a paid AI service.
What plaintiffs claimed
Plaintiffs made four different types of copyright claims. One was that defendant had directly copied Plaintiff Sage’s recording and used it in a promotional video for investors. Another was that defendant had used both of their recordings to train defendant’s AI system called Genny. They also claimed that the cloned voices produced by Genny were infringing. Finally, they argued that defendant should be liable for contributory infringement because it let its customers use those clones.
What the court decided
The court allowed one copyright claim to move forward. Plaintiff Sage alleged that defendant used a real recording of her voice in public investor presentations and YouTube videos. Defendant admitted to using a portion of the recording, and the court agreed that this could be outside the scope of the license.
The other copyright claims were not as successful. The court dismissed the copyright claim based on use of the voice recordings to train the AI model. Plaintiffs did not explain in their complaint how the training process worked or how it infringed their rights. The court said plaintiffs could amend the complaint and try again.
The court also dismissed the claim based on the AI-generated voices themselves. It explained that copyright law does not protect imitations of a voice, only the actual recordings. Plaintiffs had not alleged that the AI clones were identical to the originals, only that they sounded very similar. That kind of mimicry was not covered by copyright law.
Finally, the court dismissed the contributory infringement claim. Since there was no direct infringement based on the AI-generated outputs, the court said there could be no indirect liability either.
Lehrman v. Lovo Inc., — F.Supp.3d —, 2025 WL 1902547 (S.D.N.Y., July 10, 2025)
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