Noriega suing Activision.

Manuel Noriega, the former dictator of Panama, is suing Call of Duty's video games publisher.

The ex-military ruler is seeking lost profits and damages after a character based on him featured in Activision's 2012 title Black Ops II.

The 80-year-old 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.

Manuel Noriega
The US helped oust its one-time ally 25 years ago
"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."

'Enemy of the state'
In Activision's video game, Noriega initially helps the CIA capture a Nicaraguan terrorist, but later turns on the Americans and is hunted himself.

In reality, 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.

Call of Duty: Black Ops II
Manuel Noriega's lawyers claim that his inclusion in the game helped boost its sales
A 13-page document filed in 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