Lehrman v. Lovo Inc.

District court denies in part and grants in part AI startup's motion to dismiss claims by voice actors involving creation and use of AI-generated voice clones, allowing breach of contract and right of publicity claims to proceed but dismissing federal trademark claims and most copyright claims.

Plaintiffs Paul Lehrman and Linnea Sage, both professional voice actors, brought a putative class action against Lovo Inc., an artificial intelligence (AI) voice-over software company, alleging that Lovo unlawfully used their voices to create and sell AI-generated voice clones.

In 2019 and 2020, Lehrman and Sage were hired through online platform Fiverr by individuals later revealed to be Lovo employees. They were told their recordings would be used solely for internal and academic research. Instead, Lovo used the recordings to train its AI voice generator, "Genny," and created voice clones marketed under the names "Kyle Snow" and "Sally Coleman." These clones were sold to