When a crash game featuring a cartoon airplane launched on a Georgian betting platform in January 2019, few could have predicted it would spawn one of the most complex and geographically sprawling intellectual property battles in online gambling history. Let alone the most popular crash game of all time.
Seven years on, that dispute has landed firmly in London's Rolls Building, and a ruling handed down in May 2026 has added a fresh layer of legal complexity to a case that shows no sign of resolution any time soon.
A dispute built over years
To understand the significance of the May 2026 judgment, it helps to trace how the conflict arrived in an English courtroom.
The origins lie in Georgia, where Teimuraz Ugulava – who is himself named as a party in the current UK proceedings – developed the Aviator name and logo.
The trademark was registered in 2018, and the crash game launched in January 2019 on Adjarabet, at the time still under Ugulava's ownership. Flutter Entertainment subsequently acquired Adjarabet later that year, but crucially, the rights to the Aviator trademark were not included in the sale.
Spribe, the Estonian-registered supplier that developed the game's software, has consistently maintained that it created Aviator in 2018 and owns the IP globally. From December 2019 it began distributing the game internationally – including in the UK from February 2020 – using its own version of the Aviator imagery.
It is that imagery, and who created or copied it, that sits at the heart of the litigation.
The dispute escalated sharply in August 2024 when Georgia's Court of First Instance ruled in favour of Aviator LLC, awarding $330m in damages against Spribe and Flutter-owned Adjarabet and invalidating Spribe's Georgian trademark registrations.
Flutter, calling the damages figure "egregious," appealed and then – notably – settled with Aviator in January 2025, signing a long-term commercial partnership.
Spribe, however, fought on.
Its appeal to Georgia's Supreme Court was dismissed in May 2025, cementing the Georgian legal position against it. Undeterred, Spribe secured an interim injunction from the UK High Court in August 2025 preventing Aviator LLC from launching or marketing its own crash game in the UK – a significant reversal of fortune on British soil.
Aviator LLC has, however, continued to pursue invalidation actions before the EUIPO and has now brought the present proceedings in England.
What did this latest ruling actually decide?
The judgment handed down by Deputy Judge Michael Tappin KC on 22 May 2026 is not a final ruling on copyright ownership or infringement. It is a procedural decision – but a consequential one that will shape the architecture of the trial to come.
The core question before Tappin KC was deceptively technical: when assessing whether the earlier Georgian court rulings create binding "issue estoppels" – that is, findings that prevent a party from re-arguing points already decided against them – which country's law should govern that assessment?
There is no single English-law shortcut that resolves the question globally
Aviator LLC argued that English law should apply across the board, including in relation to copyright claims brought under the laws of multiple countries that have signed up to the Berne Convention on copyright.
The practical effect of winning this argument would have been significant: it would have allowed Aviator to use the Georgian judgments to lock in favourable findings across a wide range of international copyright claims in one fell swoop.
Tappin KC rejected that approach. Drawing on EU-derived private international law rules now assimilated into English law – specifically a regulation known as Rome II – he concluded that when assessing the binding effect of a prior judgment in relation to a claim governed by foreign law, it is that foreign law, not English law, that must be applied.
In simpler terms: for each country where Aviator is claiming copyright protection, the court must look at that country's own legal rules to decide whether the Georgian rulings settle the matter there. There is no single English-law shortcut that resolves the question globally.
He also declined Aviator's application for a preliminary trial specifically on copyright ownership, finding the issue too entangled with disputed facts and questions of Georgian law to be sensibly separated from the rest of the case.
Significance and what comes next
The case is dense and complex, but the practical consequences of the ruling are real, even if they are procedural in character.
Aviator LLC had sought to use the Georgian judgments as a springboard – establishing binding effect under English law that could cascade across its international copyright claims in one move.
That strategy has been closed off.
Instead, the court will need to assess the impact of the Georgian rulings country by country. In some jurisdictions, the res judicata rules – the legal principles governing when a prior court decision is treated as final and binding – are narrower than under English law, potentially meaning the Georgian decisions carry less weight than Aviator had hoped.
For Spribe, the ruling is largely a procedural win. It keeps the international copyright questions genuinely open.
A trial on preliminary issues relating to the Georgian judgments is expected to follow, with the scope and format of that exercise to be determined now that the governing law question is settled.
The broader picture
Beyond the litigation tactics, the Spribe-Aviator dispute represents something important for the industry: a stress test of how intellectual property law copes with a product that was developed collaboratively, deployed globally and commercialised at enormous scale before ownership was properly resolved.
The Aviator crash game became one of the most widely distributed products in iGaming history. For suppliers and operators active across regulated markets, the case is a pointed reminder that trademark and copyright diligence at the point of product development and partnership is not a formality.
With a full UK trial still to come, this case could still soar to new heights.
In February 2026, reports indicated Spribe's Aviator had reached 380 million unique players worldwide, making the IP at the centre of this dispute one of the most commercially valuable in the history of online casino gaming
