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In\u00a0a recent interview with The Guardian<\/em>, the legendary Hollywood actor, Morgan Freeman, expressed his distaste with AI\u2019s use of his voice.[1]<\/sup><\/a> Freeman went on to say, \u201cI get paid for doing stuff like that, so if you\u2019re gonna do it without me, you\u2019re robbing me.\u201d[2]<\/sup><\/a> Freeman went further and said that his lawyers \u201c[A]re already \u2018very, very busy\u2019 tackling unauthorized artificial intelligence uses of his voice.\u201d[3]<\/sup><\/a> While that is the last we have heard from Freeman and his legal team on the matter, this article will analyze the potential legal arguments one can bring to enjoin a company\u2019s use of artificial intelligence to use one\u2019s voice in an unauthorized manner.<\/p>\n \u00a0<\/p>\n As this is a new and evolving landscape, the best way to evaluate the merits of Freeman\u2019s case is by looking at a recent case: Lehrman & Sage v. Lovo, Inc<\/em>.[4]<\/sup><\/a> This case was brought by Paul Lehrman and Linnea Sage, two New York-based professional voice actors, who were approached by a company, Lovo, for the use of their voice for internal, academic purposes.[5]<\/sup><\/a> They brought this suit when they found out that their voices were being used for podcasts and other commercial uses under other names.[6]<\/sup><\/a> Decided on July 10th<\/sup>, 2025 by the District Court of the Southern District of New York, Judge Paul Oetkin issued a 60-page opinion.[7]<\/sup><\/a><\/p>\n \u00a0<\/p>\n Relevant to the topic at hand, the plaintiffs brought a Lanham Act claims for \u201cUnfair Competition and False Affiliation,\u201d and \u201cFalse Advertising.\u201d[8]<\/sup><\/a> In assessing the False Affiliation claim pursuant to 43(a) of the Lanham Act, a court requires \u201c(1) a showing of a mark that is distinctive as to a source of goods and (2) likelihood of confusion.\u201d[9]<\/sup><\/a> The court found that the plaintiffs satisfied prong one via them being celebrities with a distinctive voice, however, the court found the second prong wasn\u2019t satisfied as the celebrities voice wasn\u2019t used for endorsement, but was the product itself.[10]<\/sup><\/a> The court also found the false advertising claims to be insufficient as there was no real consumer confusion, and even if there was, the plaintiffs showed no injury.<\/p>\n \u00a0<\/p>\n The copyright infringement claims mostly proved fruitless by the plaintiffs.[11]<\/sup><\/a> The court found that while Lovo may have exceeded the scope of use, the plaintiffs failed to show exactly how their voices were used to train the AI model, and said that for the infringement claims, one must show actual fixed expressions were used, not intangible elements of one\u2019s voice.[12]<\/sup><\/a><\/p>\n \u00a0<\/p>\n However, the state claims brought by the plaintiffs proved to be more effective.[13]<\/sup><\/a> Under New York Civil Rights Law(Right of Publicity):<\/p>\n \u00a0<\/p>\n Section 50 prohibits the \u201cuse[] for advertising purposes, or for the purposes of trade, the name, portrait, picture, likeness, or voice of any living person without having first obtained the written consent of such person,\u201d and Section 51 provides a private right of action to any person whose voice is so used. \u201cTo establish such a claim, the plaintiff must demonstrate each of four elements: \u2018(i) usage of plaintiff\u2019s name, portrait, picture, or voice, (ii) within the state of New York, (iii) for purposes of advertising or trade, (iv) without plaintiff\u2019s written consent.\u2019\u201d<\/p>\n \u00a0<\/p>\n The court found that despite the one-year statute of limitations, since Lovo republishes the use of their voices repeatedly, the period refreshes and is therefore not expired.[14]<\/sup><\/a> Overall, the court recognizes that with the evolving nature of technology, state statutes must keep up with the times.[15]<\/sup><\/a><\/p>\n \u00a0<\/p>\n The court also went through the plaintiff\u2019s New York Consumer Protection Law, where it says the \u201cplaintiffs had adequately pled that Lovo had misrepresented the scope of rights it had.\u201d[16]<\/sup><\/a><\/p>\n \u00a0<\/p>\n While there were many legal arguments brought by the plaintiffs, many see right of publicity statutes to be celebrities\u2019 best course of action to halt the unauthorized use of their voice.[17]<\/sup><\/a> Professor Kristelia Garcia of Georgetown University says the right of publicity acts are \u201cTypically called upon by celebrities and other public figures, rights of publicity recognize a limited ability to control one\u2019s identity.\u201d[18]<\/sup><\/a> Professor Garcia also pointed to Midler v. Ford,<\/em> where the Ninth Circuit ruled for Bette Midler against Ford for using a similar voice in one of their commercials without her consent using a California Right of Publicity statute.[19]<\/sup><\/a><\/p>\n Overall, with new and evolving innovations come unique legal challenges, and for celebrities like Morgan Freeman, using state right of publicity law is the best way to protect their identity, and unauthorized use of their iconic voices.<\/p>\n \u00a0<\/p>\n Ezra Ashkenazi is a Second Year Law Student at the Benjamin N. Cardozo School of Law and a Staff Editor at the Cardozo Arts & Entertainment Law Journal. Ezra is interested in corporate and sports law. Ezra is also the current co-vice president of the Real Estate Law Society.<\/p>\n ____________________________________________________________________________________<\/p>\n [1]<\/a> Lexi Carson, Morgan Freeman Slams Unauthorized AI Voice Use, Says His Lawyers Are \u201cBusy\u201d<\/em>, Hollywood Reporter (Nov. 13, 2025),\u00a0 https:\/\/www.hollywoodreporter.com\/movies\/movie-news\/morgan-freeman-slams-unauthorized-ai-voice-use-legal-action-1236426767\/.<\/p>\n [2]<\/a> Id.<\/em><\/p>\n [3]<\/a> Lindsay Kornick, Morgan Freeman Threatens Legal Action Over AI use of his Voice: \u2018You\u2019re robbing me\u2019, <\/em>New York Post (Nov. 14, 2025), https:\/\/nypost.com\/2025\/11\/14\/media\/morgan-freeman-threatens-legal-action-over-ai-use-of-his-voice-youre-robbing-me\/.<\/p>\n [4]<\/a> Stuart D. Levi, Jordan Feirman, Mana Ghaemmaghami, New York Court Tackles the Legality of AI Voice Cloning <\/em>Skadden Publication \/AI Insights, (July 17, 2025) https:\/\/www.skadden.com\/insights\/publications\/2025\/07\/new-york-court-tackles-the-legality-of-ai-voice-cloning.<\/p>\n [5]<\/a> Lehrman v. Lovo, Inc.,<\/em> 790 F. Supp. 3d 348 (S.D.N.Y. 2025).<\/p>\n [6]<\/a> Id.<\/em><\/p>\n [7]<\/a> Levi, Feirman, Ghaemmaghami, supra<\/em> note 4.<\/p>\n [8]<\/a> Lehrman v. Lovo, Inc.,<\/em> 790 F. Supp. 3d 348 (S.D.N.Y. 2025).<\/p>\n [9]<\/a> Levi, Feirman, Ghaemmaghami, supra<\/em> note 4.<\/p>\n [10]<\/a> Id.<\/em><\/p>\n [11]<\/a> Lehrman v. Lovo, Inc.,<\/em> 790 F. Supp. 3d 348 (S.D.N.Y. 2025).<\/p>\n [12]<\/a> Id. <\/em><\/p>\n [13]<\/a> Levi, Feirman, Ghaemmaghami, supra<\/em> note 4.<\/p>\n [14]<\/a> Lehrman v. Lovo, Inc.,<\/em> 790 F. Supp. 3d 348 (S.D.N.Y. 2025).<\/p>\n [15]<\/a> Id.<\/em><\/p>\n [16]<\/a>\u00a0 Levi, Feirman, Ghaemmaghami, supra<\/em> note 4.<\/p>\n [17]<\/a> OpenAI v. Scarlett Johansson? Georgetown Law Professor Answers Legal Questions on AI-Generated Content<\/em>, Georgetown University Discovery & Impact, (Jun. 4, 2024),<\/p>\n https:\/\/www.georgetown.edu\/news\/ask-a-professor-openai-v-scarlett-johansson\/<\/p>\n