Back in 2014, Lindsay Lohan threatened to sue Rockstar Games, claiming that the character of Lacey Jones was based on her. Lacey Jones in the game is strung-out druggy actress, hounded by the press — can’t see any connection there.
Generally, you wouldn’t expect this to make court, since parodies are protected by law, but the New York Supreme court has ruled that she can proceed. This doesn’t mean that it will definitely end up in court, but Rockstar are the sort of stubborn bastards who are used to controversy and won’t back down.
They do look pretty similar...
But Reddit has worked out that's probably based on a photo of Kate Upton.