China's First AI Dubbing Case Involving IP Disputes: Pleasant Goat Wins Lawsuit

Recently, the Yuzhong District People's Court in Chongqing rendered a first-instance judgment in the lawsuit filed by Guangdong Original Power Culture Communication Co., Ltd. (hereinafter referred to as "Original Power Company") against a Chongqing-based company for copyright infringement and unfair competition. The court ruled that the defendant's operation of the "Shunhuo Haoshengyin" APP constituted infringement of information network transmission rights and unfair competition.

Original Power Company is the copyright holder of the "Pleasant Goat and Big Big Wolf" series, legally holding the copyrights for the artistic works of Pleasant Goat and Lazy Goat, as well as the copyright for episodes 1-530 of the "Pleasant Goat and Big Big Wolf" animated series. Since its premiere in 2005, the series has been continuously broadcast on numerous television stations across the country and has won multiple honors, including the "Magnolia" Award at the 14th Shanghai Television Festival and the Outstanding Works Award at the 11th Spiritual Civilization Construction "Five One Project." The images of Pleasant Goat and Lazy Goat are household names, and the related IP holds significant market recognition and commercial value.

In May 2023, the Chongqing-based company launched the "Shunhuo Haoshengyin" APP, which allowed users to download the software via Android and Apple app stores, as well as the Douyin platform. The APP featured AI dubbing and AI cover singing functions. Users who paid for membership could select voice types such as "Pleasant Little Goat" or "Lazy Little Goat" to generate audio and "videos" similar to the dubbing of Pleasant Goat and Lazy Goat, with the option to download and save the content. Additionally, some Douyin users posted "videos" created using the APP, and certain user comments mistakenly identified "Pleasant Little Goat" and "Lazy Little Goat" as Pleasant Goat and Lazy Goat, causing confusion.

In February 2024, after discovering these activities, Original Power Company believed that the Chongqing-based company had used its IP images and similar dubbing without authorization, infringing on its information network transmission rights and adaptation rights, while also constituting unfair competition. The company subsequently filed a lawsuit with the Yuzhong District People's Court in Chongqing, seeking compensation for economic losses and reasonable legal costs, as well as requiring the defendant to bear all litigation expenses.

Based on the case facts and legal provisions, the court determined that the infringement of information network transmission rights was established. Original Power Company, as the legitimate copyright holder of the Pleasant Goat and Lazy Goat artistic works, is legally entitled to information network transmission rights. The Chongqing-based company, without authorization, provided static images substantially similar to the aforementioned artistic works to members via the "Shunhuo Haoshengyin" APP, allowing users to access these images at a time and place of their choosing. This action met the criteria for infringement of information network transmission rights and constituted an infringement.

Furthermore, as the actions in question occurred between 2023 and 2024, the court applied the 2019 amended version of the "Anti-Unfair Competition Law of the People's Republic of China." In this case, the dubbing of Pleasant Goat and Lazy Goat was deemed a "protected identifier with certain influence," and the actions in question were sufficient to cause public confusion, thereby constituting unfair competition.

This case highlights the core challenges of IP protection in the AI era, establishing that animated character dubbing can be protected as an identifier under anti-unfair competition law, providing important guidance for the adjudication of similar cases.