Why Rudy Giuliani wants Noriega to get his bloody hands off Activision's Call of Duty profits

Activision knows something about firepower. After former Panamanian military dictator Manuel Noriega sued Activision Blizzard for using his image without paying him royalties in 2012’s first-person shooter Call of Duty: Black Ops II, Activision rolled out former New York Mayor Rudy Giuliani as its lawyer to defend the lawsuit. Giuliani, a former U.S. Attorney and former First Amendment litigator, moved to dismiss Noriega’s lawsuit yesterday — which also indicated that Noriega was portrayed in a negative light — as absurd.

Activision Blizzard makes more than a billion dollars a year in revenues from Call of Duty games, which are played by about 40 million people. But the company is also fighting for the legal right, which it says is guaranteed by the First Amendment, to create fictionalized stories around real-life characters.

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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.