The ex-military ruler is seeking lost profits and damages.
Manuel Noriega, 80, is currently serving a jail sentence in Panama for crimes committed during his time in power, including the murder of critics.
One lawyer said this was the latest in a growing trend of such lawsuits.
“In the US, individuals have what’s called the right to publicity, which gives them control over how their person is depicted in commerce including video games,” explained Jas Purewal, an interactive entertainment lawyer.
“There’s also been a very well-known action by a whole series of college athletes against Electronic Arts, and the American band No Doubt took action against Activision over this issue among other cases.
“It all focuses upon the American legal ability for an individual to be only depicted with their permission, which in practice means payment of a fee.
“But Noriega isn’t a US citizen or even a resident. This means that his legal claim becomes questionable, because it’s unclear on what legal basis he can actually bring a case against Activision.”
In Activision’s video game, Manuel Noriega initially helps the CIA capture a Nicaraguan terrorist, but later turns on the Americans and is hunted himself.
In reality, Manuel Noriega did work as a CIA informant before the agency broke ties with him. After the US became concerned about his violent rule, President George Bush ordered the invasion of Panama in 1989, which resulted in his capture.
A 13-page document filed in Manuel Noriega’s name claims that he is portrayed as a “kidnapper, murderer and enemy of the state” responsible for “numerous fictional crimes” in Black Ops II, according to Courthouse News Service.
It alleges his inclusion heightened the game’s sense of realism, helping boost its sales.
Black Ops II – which was scripted by David Goyer, screenwriter of the recent Batman movies – was 2012’s biggest-selling title in the US, UK and elsewhere.
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