Call of Duty: Black Ops 2 Draws Lawsuit from Former Panama Dictator

Former military dictator Manuel Noriega sues Activision for what he says is the "blatant misuse, unlawful exploitation, and misappropriation for economic gain" of his image in the 2012 game.

Please use a html5 video capable browser to watch videos.
This video has an invalid file format.
Sorry, but you can't access this content!
Please enter your date of birth to view this video

By clicking 'enter', you agree to GameSpot's
Terms of Use and Privacy Policy

Former Panamanian dictator Manuel Noriega has launched a lawsuit against Activision over 2012 first-person shooter Call of Duty: Black Ops II. According to a report from the Courthouse News Service, Noriega is taking legal action against the megapublisher for the "blatant misuse, unlawful exploitation and misappropriation for economic gain" of his image in the popular game.

Noriega was the military dictator of Panama from 1983 to 1989, until he was ousted. The 80-year-old now lives in Panama. As part of his lawsuit, Noriega claims: "In an effort to increase the popularity and revenue generated by Black Ops II, defendants used, without authorization or consent, the image and likeness of plaintiff in Black Ops II."

Call of Duty: Black Ops II launched in November 2012 and generated $1 billion in revenue in under a month.

Noriega goes on to claim that Black Ops II's portrayal of Noriega depicted him as "the culprit of numerous fictional heinous crimes, creating the false impression that defendants are authorized to use plaintiff's image and likeness. This caused plaintiffs to receive profits they would not have otherwise received."

The former dictator goes on to say that Call of Duty: Black Ops II depicts Noriega as a "kidnapper, murderer, and enemy of the state." He adds in the 13-page lawsuit filed in Los Angeles County Superior Court that Activision intentionally chose to feature several nonfiction characters, including Noriega, to "heighten realism" for the game and in turn boost sales.

One mission in Call of Duty: Black Ops II--called Suffer With Me--features protagonists Alex Mason and Frank Woods tracking Noriega to a compound where they eventually capture him. The game also features the likenesses of well-known government people like John F. Kennedy and Robert McNamara (oh, and the band Avenged Sevenfold, too).

"Defendants deliberately and systematically misappropriated plaintiff's likeness to increase revenues and royalties, at the expense of plaintiff and without the consent of plaintiff," the lawsuit claims.

Noriega is represented by Girardi & Keese. He is seeking damages for unjust enrichment, unfair business practices, and violation of common-law publicity rights. In addition, Noriega hopes to collect punitive damages for "lost profits" and other charges, according to the lawsuit.

Noriega is not the first high-profile person to sue over a video game. Earlier this month, actress Lindsay Lohan sued Take-Two Interactive, claiming its subsidiary--Rockstar Games--used her image without permission for the record-breaking open-world game Grand Theft Auto V.

The products discussed here were independently chosen by our editors. GameSpot may get a share of the revenue if you buy anything featured on our site.

Got a news tip or want to contact us directly? Email

Join the conversation
There are 98 comments about this story