The owners of "The Play Pen," ESS Entertainment 2000, took Rockstar Games to court on the grounds of trademark infringement. According to ESS Entertainment 2000’s argument "The Pig Pen" in East Los Santos was actually a depiction of their "The Play Pen" that they own in East Los Angeles. They further claimed that the name and logo of the virtual strip club constituted infringement.

Judge O’Scannlain, Senior US Circuit Judge for the Eighth Circuit ruled it differently.  "A reasonable consumer would not think a company that owns one strip club in East Los Angeles, which is not well known to the public at large, also produces a technologically sophisticated video game like San Andreas." He continues "Considering all of the foregoing, we conclude that Rockstar’s modification of ESS’s trademark is not explicitly misleading and is thus protected by the First Amendment.

If you’re into interesting reading, you can read the whole judgement here.