Smallville S09E05 Roulette has a cheesy reference to GTA at about 28 minutes in.
Lois tries to track down the GPS tracker in Oliver's car and finds it parked on a street corner, abandoned. Victoria comes up behind her and claims that it's her car. She tells Lois to back off and when Lois refuses, she attacks. The two fight until Victoria draws a gun and takes her captive.
Victoria: If you're not lost, then get that way. I don't like smudge marks on my car.
Lois: Nice try Vice City, go Grand Theft someone elses Auto. I've sat in that excuse for a front seat enough to know that this car belongs to Oliver Queen.
Victoria: Oh, well if you know Oliver, you know he likes to give gifts. This is one of them.