It's happened at times, mostly small things with a few big exceptions like this thing, but it was usually caught way before a game went on sale or went live because it was part of a job to make sure this kind of thing never happened.
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I would like to know the backstory on that one
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There's not a lot to be known, they pushed an update with new areas that they'd not done a very thorough job checking, which included some likely copyright-violating textures that they must have kept from when they were doing the PS3 port of Bioshock.
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