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Former Panamanian military dictator Manuel Noriega once battled it out with the United States government. Now, he might face his toughest challenge yet: a game publisher’s lawyers.

Noriega has sued Call of Duty publisher Activision for exploitation of his image. The former general filed a complaint that claims the publisher used him in Call of Duty: Black Ops II to “increase revenues and royalties at the expense” of Noriega, as first spotted by Courthouse News. The former dictator is also suing for damages because he claims that the game portrayed him in a negative way. The Call of Duty franchise has often brought in famous real-world political and military figures to add flavor to its games’ narratives, but Noriega is the first person to take issue with it.

“[Activision’s] use of [Noriega’s] image and likeness caused damage to the plaintiff,” reads Noriega’s complaint to California Superior Court. “Plaintiff was portrayed as an antagonist and portrayed as the culprit of numerous fictional heinous crimes, creating the false impression that the defendants are authorized to use plaintiff’s image and likeness. This caused the defendants to receive profits they would not have otherwise received.”

Maybe Noriega has a sizable fan club that I’m not aware of, but I doubt Call of Duty: Black Ops II’s sales would have taken a hit if it didn’t feature the former leader of Panama.

As for those “fictional heinous crimes,” Noriega says Activision’s shooter shows him as a “kidnapper, murderer, and enemy of the state.” This Call of Duty even features a mission to capture Noriega.

In reality, Noriega is a convicted felon in the U.S. and France. He worked with the U.S. Central Intelligence Agency in the 1950s into the 1980s. By 1983, he took over the Latin American nation using his military power, and he served as dictator until 1989. That year, the U.S. Army invaded the nation to oust him. One of the military’s tactics included playing incredibly loud rock music into Noriega’s hideout until he surrendered.

In 1992, Noriega faced trial in Miami. The jury convicted him of drug trafficking, racketeering, and money laundering. He got a 40 year prison sentence that was later reduced to 30 years. In 2007, the U.S. extradited Noriega to France where he got a new 7 year sentence for drug trafficking and money laundering.

While Noriega is a convicted criminal, he was never found guilty of the things Call of Duty: Black Ops II has him doing, but that doesn’t really matter.

The entertainment lawyer Jas Purewal told the BBC that Noriega is basing his case on legal rights that typically only apply to U.S. citizens.

“Noriega isn’t a U.S. citizen or even a resident,” Purewal told the BBC. “This means that his legal claim becomes questionable because it’s unclear on what legal basis he can actually bring a case against Activision.”

Noriega is currently serving a 20 year sentence in Panama for human-rights violations.


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