In a major procedural development within the online gaming vertical, international software provider Spribe has secured a defining victory in its high-stakes copyright battle against Aviator LLC before London’s High Court.
Private International Law Supersedes English Choice
The intense intellectual property dispute, which centers on the global ownership rights to the multi-billion-dollar Aviator crash game format, took a significant turn when Deputy Judge Michael Tappin KC ruled that foreign law, rather than English law, will govern the primary foundational elements of the case.
The decision of London’s High Court establishes the legal framework for how judgements from Georgian courts must be treated under international protocols, effectively dictating whether specific elements of the multi-jurisdictional trademark dispute can be legally re-argued in separate courts.
Aviator LLC, originally established by prominent Georgian entrepreneur Temur Ugulava, is actively pursuing parallel copyright infringement claims across multiple international territories under the terms of the Berne Convention. The core of the legal battle focuses on the exclusive design rights to the plane graphic that defines the interface of Aviator-branded crash titles, which have evolved into some of the most successful, high-yield online casino games worldwide.
Spribe, which distributes its proprietary version of the Aviator crash game across hundreds of licensed international operator networks, maintains that it holds all corresponding global trademarks and firmly denies any copying allegations. The software supplier previously secured an interim injunction against Aviator LLC in August 2025, allowing it to keep its game active in international lobbies until a full trial on the merits is completed.
Ownership and Infringement Deferred to Full Trial
Aviator LLC had aggressively lobbied the London court to enforce English common law when determining if existing judgements handed down by courts in Tbilisi carry a preclusive effect. Rejecting Aviator LLC’s motions, Deputy Judge Tappin KC ruled that EU-derived private international law rules remain firmly embedded within English jurisprudence post-Brexit, requiring UK judges to evaluate the specific national laws of each individual sovereign territory where copyright protection is actively claimed.
Tappin KC detailed the cross-border legal rationale in his formal judgment:
“…a rule of law relating to preclusive effect, which states whether a party is prevented from disputing (or establishing, as the case may be) one or more elements of a cause of action for an infringement of an intellectual property right, is part of the applicable law under Articles 8 and 15.”
Concurrently, Tappin KC denied a separate application filed by Aviator LLC requesting an isolated, preliminary fast-track hearing focused solely on product ownership, determining that the matter was too deeply connected to disputed facts and Georgian corporate law to be separated from the primary litigation:
“I can see no reason why ownership should be plucked out from all the other issues and decided in advance.”
