Activision brings in ex-NYC mayor Rudy Giuliani as it moves to dismiss Manuel Noriega's 'absurd' Call of Duty lawsuit

Call of Duty games make $1 billion within a few weeks of launch every year. That’s no doubt one reason why former Panamanian military dictator Manuel Noriega sued Activision Blizzard for using his image without paying him royalties in 2012’s Call of Duty: Black Ops II.

Activision said in a press release today that it will file a motion to dismiss the “frivolous” lawsuit by “former dictator and convicted murderer Manuel Noriega.” Former New York City Mayor and U.S. Attorney Rudy Giuliani, who is now a partner at Bracewell & Giuliani, will serve as co-counsel and defend the company on the grounds that Noriega’s depiction in Call of Duty is protected speech.

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Dean Takahashi

Dean Takahashi is editorial director for GamesBeat. He has been a tech journalist since 1988, and he has covered games as a beat since 1996. He was lead writer for GamesBeat at VentureBeat from 2008 to April 2025. Prior to that, he wrote for the San Jose Mercury News, the Red Herring, the Wall Street Journal, the Los Angeles Times, and the Dallas Times-Herald. He is the author of two books, "Opening the Xbox" and "The Xbox 360 Uncloaked." He organizes the annual GamesBeat Next, GamesBeat Summit and GamesBeat Insider Series: Hollywood and Games conferences and is a frequent speaker at gaming and tech events. He lives in the San Francisco Bay Area.