How come Michael Jordan was rarely in basketball video games?

I remember there were a few games like Bulls vs. Blazers etc. which had Michael Jordan but most of the other basketball games had substitute players like player 23 or player 96. Why was this?How come Michael Jordan was rarely in basketball video games?
During his playing career, he was not a member of the NBA's Players Union. It is the license from the union that grants the likenesses of the players, so since he was not a member of the union, the game developers could not use his likeness. I can't imagine that getting his likeness straight from him was inexpensive at all, so no developer bothered to do it. In several games I remember as a kid (sorry, I can't remember specific titles), if you named a player "Michael Jordan", his stats would automatically load in and the announcers would use his name during the games.How come Michael Jordan was rarely in basketball video games?
Michael Jordan played basket a pretty long time ago so he is in very old games.