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Rockstar Games put another Grand Theft Auto: San Andreas lawsuit behind it this week, as an appellate judge has dismissed a misappropriation of likeness case brought against the developer by a Cypress Hill backup singer. Washington, accused Rockstar of using his likeness and life as the basis for San Andreas protagonist CJ. Washington, who is listed in the game's credits as a model, said he was tricked into meeting with Rockstar employees and "giving up the details of [his] life" in a meeting.

Washington is listed in the game's credits as a model. Washington's appeal fared no better, with the judge ruling that Washington had offered little evidence Rockstar had in fact used him as the basis for CJ.

Even if the studio had based the character partly on Washington, it would likely have been protected as a transformative use of his likeness, the judge ruled. He referenced a similar case brought against Sega over Ulala, the main character of its Space Channel 5 games.

The publisher was sued by Kieran Kirby, lead singer of Deee-lite, who accused the game maker of taking her likeness for Ulala. A judge found that Ulala was more than a mere likeness or literal depiction of Kirby, with a different physique, hairstyle, costume, set of dance moves, and job Ulala was a reporter in the 25th century.