Tilly Norwood: AI Stardom and Its Legal Limits

In September 2025, at the Zurich film festival, artificial intelligence (“AI”) talent studio Xicocia unveiled one of the first AI generated film stars.¹ Xicocia named the new star Tilly Norwood and intend for her, along with other developing AI actors, to be licensed out for film use while maintaining a generated “backstory” and “personal life.”² Despite significant public pushback to AI usage in the film industry, including the lengthy 2023 SAG-AFTRA strike, Norwood has generated some interest among film studios and talent agencies.³ According to Norwood’s creator, Eline Van der Veldson, synthetic stars' appeal lies in the fact they “never tire, never age, and can interact with fans.”⁴ However, synthetic performers like Norwood pose serious legal concerns, especially as they relate to intellectual property and tort law.  

Most importantly, there is an issue concerning the ownership of Norwood’s character and who personality rights and copyrightability are attributable to. Personality rights generally fall under two categories: the right to publicity and the right to privacy.⁵ Traditional actors own their personality rights including control over their name, image, and likeness.⁶ While some may argue that personality rights should instead be assigned to Norwood’s creator company, courts have repeatedly denied corporations the ability to bring actions under personality right theories because corporations are fictitious, do not have feelings, and cannot be emotionally injured by torts.⁷  

As to copyrightability, a similar issue arises. In Thaler v. Perlmutter, the D.C. District Court claimed that “human authorship is a bedrock requirement of copyright,” finding that AI generated visual art was not eligible for copyright protection.⁸ However, the Thaler court did indicate that an AI generated work may be copyrightable if it had an acceptable level of human input, but the court did not explore exactly where that threshold lies.⁹ This poses a unique issue for Norwood’s content where it may be deemed uncopyrightable and subject to endless infringement. Without the added ability to pursue torts claims, Norwood’s character could become tarnished by those averse to her creation causing her to become unmarketable. The stipulation of such issues should be considered in negotiations of Norwood and other AI actors with film studios. 

Even if Norwood’s content is deemed to be copyrightable or protectable through alternative tort claims, there are potential issues surrounding copyright infringement of other actor’s works. Notably, Norwood was created using generative AI that was trained on thousands of copyrighted performances.¹⁰ Norwood’s performances and social media posts may infringe on others, especially if they are substantially similar to the original work, such that an ordinary observer would overlook any disparities between the two unless he set out to look for them.¹¹ Similar cases have already been brought against AI companies by artists whose art have been used to train to generative AI through large data sets.¹² Norwood and her AI counterparts are incapable of producing true original creations so it seems entirely possible that their performances will impermissibly rely on the styles, influences, and methods of the actors they were trained on at some point in their careers.  

While the public continues to debate the morality of AI actors like Tilly Norwood, it is clear that the legal framework surrounding their use is less than complete. It is foreseeable that the arrival of Tilly Norwood and her counterparts will shake up entertainment law.

Sources:

[1] Stuart Heritage, Tilly Norwood: How Scared Should We Be of the Viral AI ‘Actor’?, The Guardian (Sep. 30, 2025, at 17:03 ET), https://www.theguardian.com/film/2025/sep/30/tilly-norwood-ai-actor-hollywood. 

[2], [3], [4] Witney Seibold, Who Is Tilly Norwood? Hollywood's Controversial AI-Generated Actress Explained, Slash Film (Sep. 29 2025, at 16:30 ET), https://www.slashfilm.com/1982132/tilly-norwood-hollywood-ai-generated-actress-explained/. 

[5], [6] 1 Art Law Deskbook § 3.03 (2026).  

[7] Stacy Allen et al., Non-human Persons and the Right of Publicity, Jackson Walker 61, 72 (Dec. 1, 2008), https://www.jw.com/wp-content/uploads/2019/08/1185.pdf. 

[8], [9] Thaler v. Perlmutter, 687 F. Supp. 3d 140, 146 (D.D.C. 2023). 

[10] Stacey B. Lee, The Tilly Norwood Problem: When AI Innovation Turns into Abdication, John Hopkins Carey Business School (Oct. 31, 2025), https://carey.jhu.edu/articles/tilly-norwood-problem-when-ai-innovation-turns-abdication. 

[11] Boisson v. Banian, Ltd., 273 F.3d 262, 272 (2d Cir. 2001). 

[12] Yunah Kwon, Copyright in the Age of Generative AI, Part II: Reinterpreting DMCA 1202 and Encoded Representations, Columbia Undergraduate Law Review: Current Events (Aug. 31, 2025), https://www.culawreview.org/current-events-2/copyright-in-the-age-of-generative-ai-part-ii-reinterpreting-dmca-1202-and-encoded-representations.