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Manuel Noriega Sues Over 'Call of Duty' Video-Game Likeness

By Brett Snider, Esq. on July 21, 2014 | Last updated on March 21, 2019

Imprisoned ex-dictator Manuel Noriega is suing the makers of "Call of Duty: Black Ops II" for allegedly harming his reputation and using his name and likeness without permission.

The Activision Blizzard Inc. game, which has made more than $1 billion in worldwide sales, includes a mission in which the protagonists must track down Noriega and capture him, reports Gamespot. Noriega's lawsuit claims the game portrays him as a "kidnapper, murderer, and enemy of the state" and used that virtual vilification to profit.

Does Noriega have a case against his fictional portrayal in a video game?

Noriega Painted as 'Call of Duty' Killer

Noriega is currently serving 20 years in a Panamanian prison after being released from France, where he was convicted of murder and money laundering. But this whole "Call of Duty" portrayal as a killer is apparently getting under his skin.

Here's a clip of his portrayal as a video game villain:

Courthouse News Service reports that Noriega was ousted as Panama's dictator in 1989 by U.S. forces, and was eventually convicted in the United States of drug dealing, racketeering, and money laundering.

Sound like the guy in the video? Well despite all of these criminal convictions and a pretty tarnished historical record, Noriega believes that the real villain here is Activision Blizzard. However, according to CNS, Noriega isn't suing for defamation; he's only seeking compensation for the fact he wasn't paid to be portrayed as a video game villain.

Video Game Likeness Rights

As we should have all learned by now care of EA Sports, you generally can't use someone's name and/or likeness in a video game without paying him or her for it. And while NCAA basketball players don't share much in common with Noriega, they both have legal rights to their image and persona -- also known as the rights of publicity.

CNS reports that Noriega alleges Activision Blizzard "misappropriated plaintiff's likeness to increase revenues and royalties" without the former CIA puppet's consent. Under a theory of unjust enrichment, Noriega could have a court create a financial obligation between Activision Blizzard and the infamous prisoner, potentially entitling him to a cut of the game's profits.

Perhaps not recognizing the irony, Noriega is also hoping a jury will award him punitive damages for the malicious and deliberate actions of the "Call of Duty: Black Ops II" game makers.

Maybe the former dictator's litigation drama will be added as DLC for the next installment of "Call of Duty."

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