Deepfakes, Copyright, and Personality Rights: A Cross-Jurisdictional Analysis

A major threat to privacy, identity and intellectual property rights has been the rapid rise of deepfake technology, an artificially intelligent type of media manipulation, which can create hyper-realistic manipulations. Although deepfakes have been deployed in such creative ventures as art and satire, their nefarious applications in political manipulation, defamation, and non-consensual explicit material have brought immediate concerns to the legal sphere. This paper traces the use of deepfakes in criminal law, focusing on the implications of deepfake usage on copyright law and personality rights in the contexts of the Indian, the United States, and the European Union jurisdictions. Using real life situations like the one on Lindsay Lohan. Take-Two Interactive and Rana Ayyub verus. The doctrine as addressed in the paper illustrates the exposure of individuals to the right of publicity and privacy in the world of digital manipulation, aka Deepfake Pornography Campaign. It points to the inadequacies in the current legal systems that leave the individuals without an appropriate legal remedy because the extent of the harm the individuals have suffered is not covered by legal frameworks. Among the possible solutions, the paper also speaks about the training of AI-based deepfake detectors, the emergence of international legal frameworks, and the reshaping of the existing laws related to defamation and privacy. It suggests the thorough amendment of the law to defend the digital likeness of individuals and personal rights based on examining legal precedents. The developing nature of deepfake technology requires versatile response, implemented by the use of law, technological measures, and cross-border cooperation to uphold the rights of individuals in the era of the Internet.