Manuel Noriega in Call of Duty: Black Ops II

The studios behind the Call of Duty series may have garnered some extra sales by putting real people into their over-the-top shooters, but it looks like that strategy could land them in court. Former Panamanian dictator Manuel Noriega has sued the games' publisher, Activision, for using his likeness in Call of Duty: Black Ops II without his permission. He argues that he's entitled to damages because his presence both violated his publicity rights and helped "heighten realism," leading to added profits that should have been his.

There's no doubt that it's Noriega in the game, but he may have a tougher time getting a check from game developers than, say, college football players. As attorney Jas Purewal tells the BBC, Noriega isn't an American resident and might not even get his foot in the door. He's also a historical persona, and a notorious one at that -- we wouldn't expect the courts to sympathize with his alleged plight as much as they would with an actor or star athlete that genuinely depends on his visage for a living. Activision isn't commenting, but it may not have much reason to worry even if the lawsuit goes forward.