Voice actors' voices are being cloned by AI companies using recordings they were paid $50 for on Fiverr, with no legal remedy under federal copyright law

Voice-over actors Paul Lehrman and Linnea Sage discovered that Lovo, Inc., an AI text-to-speech company, had used recordings they made through Fiverr gigs to train AI voice clones of their voices — clones that Lovo then sold commercially. The actors were originally paid small amounts for what they believed were limited-use recordings. Instead, their voices became products sold to thousands of customers, generating revenue the actors will never see. In July 2025, Judge Oetken in the Southern District of New York ruled that federal copyright and trademark law do not protect a person's voice as an abstract concept. The court dismissed the copyright claims entirely, finding that the actors sought protection for their voice attributes rather than specific recorded performances. This means that under current federal law, there is no remedy for having your voice cloned by AI — your voice is not copyrightable. For the roughly 100,000 voice actors working in the US, this creates an impossible situation: any recording they make for any client could become training data for an AI clone that replaces them permanently. The structural reason this problem persists is that voice acting has always operated in an informal economy. Most voice actors work through platforms like Fiverr, Voices.com, or direct contracts with vague or nonexistent terms about derivative works and AI training. The Lehrman court did allow breach-of-contract claims to proceed, suggesting that platform terms of service might offer some protection — but this requires voice actors to have had explicit contractual restrictions in place, which almost none of them did before 2024. State right-of-publicity laws like New York's digital replica provision and Tennessee's ELVIS Act offer partial protection, but coverage is inconsistent across states, enforcement is expensive, and most voice actors cannot afford litigation against well-funded AI companies.