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Judge Oetken dismisses most of two voice actors' claims against AI voice company Lovo, keeps a copyright claim over one actor's original recording, and lets them replead the training claim

Paul Lehrman and Linnea Sage allege that Lovo obtained their voice recordings through Fiverr in 2019 and 2020 under limited-purpose assurances, used them to train its 'Genny' voice generator, and sold clones of their voices. In a 60-page opinion on July 10, 2025, Judge J. Paul Oetken held that the Lanham Act claims fail because a voice is not a mark, and that AI-generated imitations of a voice are not copyright infringement because 17 U.S.C. § 114(b) excludes recordings that merely imitate a protected recording. He let Sage's copyright claim proceed as to Lovo's reproduction of her original recording on its website. He dismissed the claims over training Genny on the recordings, with leave to amend, because the plaintiffs never explained "what training is or how it works"; he added that Lovo's one-sentence fair use defense was insufficient for now, and that the plaintiffs plausibly alleged their chats narrowed any Fiverr license. Claims under New York Civil Rights Law §§ 50-51, consumer protection law and contract survived. Lovo moved again to dismiss the training claim in the second amended complaint. On May 28, 2026 the case was stayed after Lovo filed for bankruptcy.