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Judge dismisses Noriega lawsuit over Call of Duty

Activision Blizzard rep calls it "a victory for works of art across the entertainment and publishing industries throughout the world"

Activision Blizzard was won its legal battle with former Panamanian dictator Manuel Noriega in speedy fashion. Noriega sued the publisher in July, claiming it exploited his image and damaged his reputation by including him as a minor character in the 2012 shooter Call of Duty: Black Ops II.

A Los Angeles Superior Court judge approved Activision's motion to dismiss the suit with prejudice for a variety of reasons.

"Noriega fails to provide any evidence of harm to his reputation," the judge wrote in dismissing the case. "Indeed, given the worldwide reporting of his actions in the 1980s and early 1990s, it is hard to imagine that any such evidence exists."

Additionally, given Noriega's absence from promotional materials and limited role in the game's narrative (he appears in just two of 11 missions and has fewer than 30 lines of dialogue), the judge ruled that Activision's use of him was transformative enough to be covered by the First Amendment right to free speech.

"This ruling is an important victory and we thank the court for protecting free speech," said former New York City mayor Rudy Giuliani, whose lawfirm represented Activision in the case. "This was an absurd lawsuit from the very beginning and we're gratified that in the end, a notorious criminal didn't win. This is not just a win for the makers of Call of Duty, but is a victory for works of art across the entertainment and publishing industries throughout the world."

Brendan Sinclair avatar

Brendan Sinclair

Managing Editor

Brendan joined GamesIndustry.biz in 2012. Based in Toronto, Ontario, he was previously senior news editor at GameSpot in the US.