How so? If likeness in a video game warrants compensation, then any likeness in any video game warrants compensation...or are we narrow mindedly just talking about college football...wow...its a VIDEO GAME!!!!!
No, just the one's where it's obvious that the likeness is meant to be a specific person and that specific person enhances the marketability of the game. In the case of Keller, the 2005 EA game had the "same height, weight, skin tone, hair color, hairstyle, handedness, home state, statistics, play style (pocket passer), visor preference, facial features, and school year as Keller."
I promise you that if EA Sports made a snowboarder game featuring a rider with the same height, weight, skin tone, hair color, hairstyle, footedness, home state, riding style (big air), hat preference, and facial features as Shaun White, they would get sued stat.
Having real players in the EA NCAA football game or Shaun White in a snowboarder game enhances the value of the game. Even if you could satisfy a court that a real soldier's likeness was being used, how does that enhance the marketability of the game?