The claims suggest that EA altered player names and uniforms, but based character models for the game’s 140 ‘historic teams’ on their likenesses whilst they were still active sportsmen. The claim states:
"The only significant detail that EA changes from the real-life retired NFL players is their jersey number. Despite EA's 'scrambling' of the retired NFL players' numbers, the games are designed so that consumers of the Madden NFL video game franchise will have no difficulty identifying who the 'historic' players are."It also goes on to claim that the game allows gamers to change player names and numbers.
This is not the first time EA have been involved in such a legal spat, with over $26 million paid in 2009 to 2,000 retired players demanding royalties for the use of their likenesses.
A complete PDF of the claim can be seen here