Voice Cloning Lawsuit News: July 2025 Ruling and Case Status

The Lehrman v. Lovo voice cloning lawsuit is a federal case in which two voice actors, Paul Lehrman and Linnea Sage, sued the AI company Lovo Inc. for allegedly cloning their voices without consent after hiring them under false pretenses on Fiverr. In July 2025, a judge in the Southern District of New York allowed the actors’ state-law claims to go forward while rejecting most of their federal copyright and trademark claims. The case is currently stayed because Lovo filed for bankruptcy in May 2026.¹²

How the Dispute Started

Lehrman and Sage are New York-based voice-over actors. Lehrman has worked on television shows including Blue Bloods, New Amsterdam, and The Resident. Sage has voiced ads for major brands, a Marvel video game, and international television spots.¹

The complaint, filed May 16, 2024, alleges that Lovo employees reached out to each actor on Fiverr and misrepresented what the recordings would be used for. In May 2020, a Lovo employee using a pseudonymous screen name hired Lehrman for $1,200 and told him the audio was for “academic research purposes only.” In October 2019, Lovo co-founder Tom Lee hired Sage for $400 to record “test scripts for radio ads,” saying the recordings would be used internally and would not require rights.³

According to the lawsuit, Lovo instead fed those recordings into its AI platform, Genny, and generated voice clones it sold commercially. Lehrman’s clone was marketed as “Kyle Snow” and served as the default voice on Lovo’s platform from 2021 through September 2023. Sage’s clone, “Sally Coleman,” was played alongside her real voice during a 2020 investor pitch at Berkeley SkyDeck Demo Day, with the presentation later posted to YouTube.⁴ Neither actor received any compensation beyond the original Fiverr fees.³

The actors filed as a putative class action on behalf of other voice performers whose voices were allegedly cloned, seeking more than $5 million in damages and an injunction blocking further use of their voices.⁴ Before the suit was filed, Lovo responded to a cease-and-desist letter by saying the voices were “fully permissioned” and that it had voluntarily taken the characters down. The plaintiffs dispute both claims.¹

What the July 2025 Ruling Decided

On July 10, 2025, Judge J. Paul Oetken issued a 60-page opinion on Lovo’s motion to dismiss. The result was split: most federal intellectual property claims were thrown out, but the state-law claims that form the heart of the case were allowed to continue.¹

Claims That Survived

The judge let four categories of claims proceed.

Breach of contract. The Fiverr chat exchanges included enough detail about price, scope, and usage restrictions to form enforceable contracts, and electronic messages identifying material terms were sufficient to satisfy the Statute of Frauds.
New York right of publicity, under Civil Rights Law §§ 50 and 51. The court held that these statutes protect living people from the unauthorized commercial use of their voices, and that AI-generated voice clones count as a “recognizable representation of a person’s identity.” A 2021 amendment adding protections for digital replicas of deceased performers did not strip protections already available to the living.
Consumer protection, under General Business Law §§ 349 and 350. The actors adequately alleged that Lovo misled customers by claiming it could grant full commercial rights to voice clones when those rights were contested.
One copyright claim. Sage’s allegation that Lovo used her actual voice recording in investor presentations and YouTube videos beyond any license was allowed to proceed as a straightforward unauthorized-use claim.

The court also gave the plaintiffs permission to re-plead a copyright claim tied to how Lovo used the recordings to train its AI model. The original pleading was too thin, but the judge did not foreclose the theory.⁵

Claims That Were Dismissed

The federal IP theories fared poorly.

Lanham Act (federal trademark). The court concluded that a voice, in this setting, does not function as a trademark. The actors’ voices were “tools of their trade” rather than brands, and the plaintiffs had not shown their voices carried the kind of secondary meaning needed to serve as source identifiers.¹
Copyright Act (most claims). The judge held that copyright does not protect a voice itself or “the imperfect voice mimicry” produced by AI. Protection for a sound recording does not extend to the “independent fixation of other sounds” that imitate the original, so new audio generated by Lovo’s AI that mimicked vocal characteristics was not actionable copying.⁶
Common-law claims. Fraud, unjust enrichment, conversion, and unfair competition were dismissed as duplicative of the surviving claims or preempted by the New York right of publicity statute.⁵

Why the Decision Matters

The practical message of the ruling is that federal intellectual property law, as it stands, offers little help to people whose voices are cloned by AI. The court said New York’s Civil Rights Law was better “tailored to balance the unique interests at stake” than copyright or trademark law. Future plaintiffs will likely need to anchor voice-cloning cases in state right-of-publicity statutes rather than federal IP frameworks.¹

The judge also addressed timing. Lovo argued that any claim had to be filed within one year of the original recordings. The court rejected that, finding that because the AI model was trained on the plaintiffs’ voices and continued to generate clips using those voices, the violation was ongoing rather than a single past event.⁵

Where the Case Stands Now

The plaintiffs filed a Second Amended Complaint on July 31, 2025, taking the court up on its invitation to re-plead the AI-training copyright claim.⁷ Oral argument on a new motion to dismiss was scheduled for June 16, 2026, and the case appeared to be moving toward discovery.

That argument never took place. On May 27, 2026, Lovo filed a suggestion of bankruptcy, and Judge Oetken stayed the entire case the following day, adjourning all conferences and deadlines. No class certification motion had been filed before the stay. The litigation remains frozen pending further order from the court.²

The plaintiffs are represented by Pollock Cohen LLP in New York. After the July 2025 ruling, partner Steve Cohen called the decision “a spectacular victory for the plaintiffs” and said the firm looked forward to taking the case to a jury.⁸ Whether that happens depends on how the bankruptcy proceeds.

What the Case Does Not Decide

If you came to this case looking for a ruling that AI voice cloning violates federal law across the board, this is not that ruling. The court was explicit that neither copyright nor the Lanham Act currently reaches AI-generated voice mimicry on its own. Protection in this case runs through New York state law and the contracts the actors signed on Fiverr. The outcome in another state, or in a case without a clear contract trail, could look very different.

Federal law in this area is still in flux. The FCC declared AI-generated voices in robocalls illegal under the Telephone Consumer Protection Act in February 2024, but that rule addresses robocalls, not commercial voice cloning generally.⁹ The No AI FRAUD Act was introduced in the House in January 2024 but died when the 118th Congress ended.¹⁰ The NO FAKES Act, reintroduced on May 20, 2026, would create a federal right allowing individuals to control their own voice and likeness and to sue those who knowingly create or profit from unauthorized digital copies, but as of mid-2026 it has not received committee markup or a floor vote.¹¹ Tennessee’s ELVIS Act is one of the first state statutes to directly target AI-generated replicas of voices and likenesses, and California’s Civil Code Section 3344 and common law also extend right-of-publicity protection to voice.

For now, Lehrman v. Lovo is the clearest federal court roadmap we have for how an AI voice-cloning case gets evaluated, and it points voice performers toward state right-of-publicity law, contract terms, and consumer protection statutes rather than federal copyright or trademark theories.

1
U.S. District Court, S.D.N.Y. Lehrman v. Lovo, Inc., No. 24-CV-3770 (JPO)
2
PACER Monitor. Lehrman et al v. Lovo, Inc.
3
Pollock Cohen LLP. Lehrman v. Lovo, Inc. — Complaint
4
CNN. Voice Actors Sue AI Firm Lovo Over Alleged Unauthorized Voice Cloning
5
Skadden, Arps, Slate, Meagher & Flom LLP. New York Court Tackles the Legality of AI Voice Cloning
6
Thomson Reuters Practical Law. No Trademark, Copyright Protection for Voices Mimicked by AI (S.D.N.Y.)
7
ChatGPT Is Eating the World. Lehrman Filed Second Amended Complaint v. Lovo
8
PR Newswire. Pollock Cohen Wins Series of Key Rulings in Voice Cloning Case Against Lovo
9
Federal Communications Commission. FCC Makes AI-Generated Voices in Robocalls Illegal
10
GovTrack. No AI FRAUD Act (H.R. 6943)
11
U.S. Senate, Office of Senator Blackburn. Blackburn, Coons, Salazar, Dean, Colleagues Introduce Revised Version of NO FAKES Act