Manuel Noriega, the former dictator of Panama, filed a lawsuit on Tuesday against the maker of the popular Call of Duty: Black Ops II video game, saying his image was used in the game without his permission.
Mr. Noriega, who is serving a prison sentence in Panama after being convicted of money laundering, filed his suit in Los Angeles County Superior Court, claiming that Activision Blizzard, the developer of the video game, portrayed him as a “kidnapper, murderer and enemy of the state,” according to the suit. Mr. Noriega, 80, is seeking lost profits as well as damages.
A lawyer for Mr. Noriega, Graham B. LippSmith, did not immediately return a call for comment. Activision did not immediately respond to a request for comment.
The suit follows a trend that takes aim at video game developers. On July 2, the actress Lindsay Lohan sued the makers of Grand Theft Auto 5, Take-Two Interactive College and its subsidiary, Rockstar Games, claiming that they used her likeness without her permission.
A group of college athletes reached a $40 million settlement with E.A. Sports over the rights to use their images in video games, and in 2012 the band No Doubt settled a lawsuit against Activision that claimed the Band Hero video game featured its unauthorized likeness.
The issue in the Noriega case is one of the right of publicity, which can be unpredictable, said Kim J. Landsman, a partner at the New York law firm Golenbock Eiseman who specializes in intellectual property cases. “The question is whether the courts will go beyond procedural issues and decide whether someone who has been convicted of heinous acts should have a right of publicity at all,” he said, adding that he thought Mr. Noriega’s chances were “very slim.”
“If California is going to bend over backward to help a plaintiff, it shouldn’t be this guy,” he said.