With the rise of artificial intelligence, deepfakes have become easier to produce, increasingly realistic, and can now be disseminated to a vast audience on social media platforms with minimal effort. This development poses a potential threat to a democratic society. Individuals can now be depicted in situations in which they never participated, most notably in pornographic or otherwise inappropriate content, without the deepfake being recognizable as a fake. From a legal perspective, protection against such deepfakes may arise under the US Right of Publicity and the EU’s Right to One’s Own Image. Although these regimes rest on different doctrinal foundations, a comparative analysis has proven to be particularly instructive. It has clarified the underlying rational of each system and has helped to better understand the respective doctrines. The thesis demonstrates that, in the context of deepfakes, both regimes serve the same functional purpose, namely the protection against the unauthorized appropriation of a person’s identity. Moreover, the analysis addressed the significant tension between the protection of personal identity, on the one hand, and commercial interests, on the other. Furthermore, the thesis demonstrates that, especially in the context of postings on social media platforms, EU law provides broader protection than US law. However, under both legal regimes, an assessment in light of freedom of expression is unavoidable. In this context, generalized conclusions are difficult to draw, particularly under US law, due to its strongly case-based jurisprudence. Irrespective of these differences, the thesis ultimately shows that neither regime is capable of fully addressing the underlying structural problems, described in this thesis as threshold obstacles, which significantly limit effective legal protection against deepfakes. The thesis has also addressed the question whether further legislative action is required, whether such intervention would be effective at all, or whether the issue is better addressed through broader social change.