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Table Of Content :

UK Court Clarifies Foreign Judgment Rules in Aviator–Spribe Copyright Dispute

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Altay
Altay Celikkaya
Content Manager
Updated:
Reading Time: 3 minutes

The UK Court of Appeal has allowed an appeal by Aviator LLC and related companies in their continuing intellectual property dispute with gaming supplier Spribe OÜ. The judgment determines which law English courts should apply when deciding whether earlier Georgian rulings prevent the parties from re-arguing copyright issues.

The decision is an important procedural development, but it does not resolve the underlying questions of copyright ownership, copying or infringement. Those matters remain contested as the wider case continues in England.

Spribe and Aviator logos frame the UK Court of Appeal copyright ruling.

Regulation & Compliance

Key Takeaways From the Aviator–Spribe Appeal

  • The Court of Appeal allowed Aviator’s appeal against the May 2026 High Court decision.

  • English law will determine the effect of the earlier Georgian judgments in the UK proceedings.

  • Foreign copyright laws may still govern the substantive infringement claims for individual territories.

  • The court did not decide whether Aviator owns the disputed intellectual property.

  • The ruling may affect how international gaming businesses manage parallel intellectual property cases.

Court Rejects High Court Approach to Issue Estoppel

The dispute concerns competing claims over the Aviator name, game imagery, and the aeroplane device used in crash games. Aviator argues that earlier Georgian proceedings resolved several questions about copyright ownership and copying, so Spribe should not be allowed to re-litigate those points in the English court.

The High Court previously concluded that the law governing each underlying copyright claim should determine the effect of the Georgian judgments. Because Aviator’s case covers several territories, that approach could have required the court to examine multiple national laws.

In its official judgment, the Court of Appeal rejected that conclusion. It found that the law of the court hearing the current proceedings governs how a recognised foreign judgment is treated.

Lord Justice Arnold said:

I have come to the opposite conclusion to the judge.

The appeal was therefore allowed, with Lady Justice King and Lord Justice Miles agreeing.

What the Judgment Does Not Decide

The ruling should not be interpreted as a final decision that Aviator owns the relevant copyright or that Spribe infringed it. Spribe continues to dispute Aviator’s ownership claims and maintains that it independently created its designs.

The court also distinguished between procedural and substantive questions. English law governs whether the Georgian decisions create issue estoppel, while the relevant national law continues to apply to the substance of copyright claims brought for individual countries.

That distinction is central to the case. It determines how much of the dispute England can reconsider without resolving the infringement claims themselves.

Cross-Border Litigation Creates Wider iGaming Exposure

The judgment carries broader significance for game studios, platform suppliers and operators distributing products across multiple regulated markets. Intellectual property disputes can involve different national copyright rules and require courts to decide whether to recognise earlier foreign judgments.

Similar jurisdictional questions have emerged as European courts examine whether players can recover losses from operators based in another country. The European Commission’s dispute with Malta over Bill 55 and the enforcement of foreign gambling judgments also illustrates the growing importance of cross-border recognition.

National court decisions are also reshaping market obligations, including the Belgian Constitutional Court’s ruling on applying online gambling advertising restrictions.

For B2B gaming businesses, the Aviator–Spribe appeal reinforces the need to establish ownership records, licensing rights and litigation strategies before distributing a game internationally. Spribe has also been nominated for an Ace Alliance Award, reflecting its continued presence in the wider iGaming industry. The English proceedings will now continue under the legal framework the Court of Appeal clarified.