Call of Duty: Black Ops II made use of convicted murderer, criminal, and former military dictator Manuel Noriega's likeness. Back in July, Noriega decided to sue Activision for millions claiming that Black Ops II profits by portraying him as "a kidnapper, murderer and enemy of the state." Activision has lawyered up with former New York City mayor Rudy Giuliani to denounce the lawsuit as an attack on free speech with awful ramifications for other forms of media should this lawsuit be successful. Unsurprisingly, Activision has moved to have the suit be thrown out of court.
"What's astonishing is that Manuel Noriega, a notorious dictator who is in prison for the heinous crimes he committed, is upset about being portrayed as a criminal and enemy of the state in the game Call of Duty. Quite simply, it's absurd," said Giuliani. "I'm not interested in giving handouts to a convicted murderer and drug smuggler like Manuel Noriega who is demanding money from Activision and its popular Call of Duty franchise for simply exercising its right to free speech. Noriega's attack on the rights of Call of Duty comes as no surprise considering he's a lawless tyrant who trampled over the rights of his own people."
You can watch Giuliani's full statement here.
It has been a longstanding right for people to reference and portray prominent world figures in works of fiction. Hopefully this will never see a full court hearing.