A High Court of England and Wales judge has ruled that foreign law and earlier Georgian judgments must be weighed in SPRIBE's intellectual property battle over the Aviator crash game, blocking Aviator LLC's attempt to fast-track the ownership question. The procedural win decides nothing on the merits, with trademark and copyright issues deferred to a full trial.
SPRIBE, the Estonia-based developer behind the crash game Aviator, has secured a procedural advantage in its long-running intellectual property battle with Aviator LLC after the High Court of Justice of England and Wales declined to treat the dispute as a purely English matter. According to reporting on the ruling, deputy judge Michael Tappin KC handed down his decision on 22 May 2026, concluding that copyright-related questions in the case fall to be assessed under the laws of the countries where protection is claimed rather than English law alone. The judge found that earlier judgments issued by courts in Georgia could not simply be ignored, given that the claims extend across multiple territories bound by the Berne Convention, the international copyright treaty. In reaching that view, the court relied on private international law principles derived from European Union law that continue to apply in England after Brexit.
The practical effect, according to the ruling, is to block Aviator LLC's attempt to isolate the ownership question as a preliminary issue and resolve it quickly under English legal principles. The court found that the ownership dispute involved contested facts and Georgian law, and therefore could not be carved off and decided on a fast-track basis. It is important to stress that this is a procedural order and not a final verdict. The judge made no findings on who owns the Aviator brand, on the validity of any trademark, or on whether infringement took place. Those core corporate and IP questions have been reserved for a full trial, which reporting indicates is expected to commence in late 2026 or early 2027 and to run for several weeks.
The wider dispute is unusually entangled. Aviator LLC, a vehicle connected to Georgian businessman Temur Ugulava, has pressed claims that SPRIBE registered its trademarks in bad faith and infringed pre-existing rights. In August 2024 a Georgian court ruled in Aviator LLC's favour and awarded damages reported at USD $330 million (approximately GBP £244 million), while invalidating SPRIBE trademark registrations. SPRIBE, whose founder David Natroshvili has publicly maintained that the company created Aviator in 2018 and is its sole global owner, saw an appeal to Georgia's Supreme Court dismissed in May 2025. The English proceedings therefore sit on top of a contested foreign judgment, which helps explain why the High Court was unwilling to assess the matter through an English lens alone.
The 22 May order is only the latest chapter in a conflict that has spilled across continents. In July 2025 the same High Court, in a decision by Mr Justice Anthony Mann, granted SPRIBE an interim injunction restraining Aviator LLC from launching a competing crash game in the British market, although the judge declined to impose every restriction SPRIBE had sought. The litigation has also reached South America. In April 2026 the Court of Justice of Pernambuco (TJPE) in Brazil ordered Flutter-owned NSX Brasil, the company behind the Betnacional brand, to cease using the Aviator trademark and related assets, a measure backed by daily fines. According to subsequent reporting, the broader Brazilian position quickly shifted, with a São Paulo appeal court ruling against SPRIBE in related proceedings within weeks, illustrating how volatile cross-border enforcement can be. SPRIBE has separately faced an invalidation action lodged by Aviator LLC at the European Union Intellectual Property Office (EUIPO).
For SPRIBE, the value of this decision lies less in what it decides than in what it preserves. The company's case rests on a historical narrative about when and where Aviator was created and commercialised, a story that only makes sense when the international timeline stays in view. By refusing to amputate the foreign dimension, the court has kept SPRIBE's strongest argumentative asset on the table. Aviator LLC, by contrast, had a clear strategic logic in seeking a swift, narrow ruling in a respected forum: a clean English finding on ownership could have been leveraged in other markets. That route is now closed, and both sides must prepare for a long, fact-heavy trial.
The Aviator saga is a case study in jurisdictional fragmentation. The same product has produced a USD $330 million judgment against SPRIBE in Georgia, an injunction in its favour in Britain, and a win-then-loss sequence in Brazil, all within roughly two years. That pattern exposes a structural enforcement gap that operators should note via any serious regulatory map exercise: a trademark or copyright registration secured in one territory offers limited protection against parallel claims elsewhere, and national courts increasingly decline to defer to foreign decisions. Studios chasing a breakout hit cannot treat IP as a single filing; it is a portfolio that must be defended jurisdiction by jurisdiction.
It is worth keeping the scale of this development in proportion. A ruling on which law applies is a meaningful tactical gain, but it leaves the central question of ownership exactly where it was: unresolved and bound for trial. The bottom line is that SPRIBE has improved its position without winning the war. The decisive contest over who truly owns Aviator still lies ahead, and on current trajectory it will be fought in more than one country at once.
