Key Points
- Malta’s First Hall of the Civil Court issued a provisional ex parte order on 1 September 2026 against Aviator Studio Limited, Aviator Studio Holding Limited, and Aviator Studio USA Limited, covering Spribe’s EU trademarks across all member states.
- The court cited evidence of live market confusion on Betsson and EuroCasino, and noted Aviator Studio’s recently granted MGA B2B licence as a factor in assessing the risk of further spread.
- The order is provisional: Aviator Studio can challenge it, and Spribe must commence full merits proceedings within 31 calendar days of 1 September. A UK multi-territorial injunction hearing is scheduled for October.
A single court order issued in Malta on 1 September now covers every EU member state. That is the scale of what Spribe just won, and for anyone still trying to figure out which “Aviator” is which, the question just became a lot more pressing.
What the Malta Court Ordered, and Who It Hits?
The First Hall of the Civil Court of Malta issued the ex parte provisional order on 1 September 2026, naming three companies simultaneously: Aviator Studio Limited, Aviator Studio Holding Limited, and Aviator Studio USA Limited. All three must immediately stop using signs identical or similar to Spribe’s EU trademarks in connection with equivalent products and services, and must also cease operating the aviator.studio domain, or any other website featuring a comparable mark.
Spribe brought the proceedings under Malta’s Intellectual Property Rights Enforcement Act, seeking urgent precautionary measures to stop what it described as the continued infringement of its EU trademarks. The order covers two registered marks: EU trademark 018817594, a figurative mark combining the word “Aviator” with an aircraft image, and 018825078, a multimedia mark protecting the audiovisual presentation of the game itself. In its application, Spribe argued that the Aviator Studio companies had promoted what it called an imitation version of the Aviator game in a way likely to mislead players, operators, and commercial partners.
The court agreed, on a prima facie basis. It cited three overlapping factors: the identical “Aviator” name, similarities in the aircraft imagery used by both parties, and the fact that both companies target the same online gaming audience.
The Evidence of Confusion That Moved the Court
The confusion evidence the court relied on was not theoretical. According to the main article by NEXT.io, the court pointed to how both games appeared alongside each other when users searched for “Aviator” on Betsson and EuroCasino, and to a LuckyStreak listing that appeared to attribute Spribe’s game to Aviator Studio. That kind of live commercial overlap, visible to real players using real platforms, is precisely the kind of evidence courts look for when deciding whether interim protection is justified.
The court also noted that Aviator Studio Limited had recently been granted a B2B Critical Supply Licence by the Malta Gaming Authority, licence reference MGA/B2B/1096/2025. The court cited this as a factor in the circumstances supporting urgency: a newly licensed supplier, already distributing through Malta and active on Betsson in Sweden and Finland, was in a position to expand further into EU markets. That specific combination, live confusion plus imminent distribution capability, shaped the court’s reasoning on why action was needed before the defendants could be heard.
Spribe’s Founder on the Momentum
Spribe founder David Natroshvili did not understate the significance. “We are grateful that the Honourable Court of Malta has provided SPRIBE with the provisional injunction across the EU from the persistent infringement of our intellectual property rights,” he said. “This is further momentum for SPRIBE after several positive outcomes, including cancellation of the trademarks of infringers in Curaçao, and the registration of our iconic logo in Kenya. We hope the positive outcomes will continue in October in the UK, where there will be a hearing of our application for a multi-territorial preliminary injunction request.”
The October reference points to a UK Case Management Conference, where Spribe will press its application for a multi-territorial preliminary injunction, a step that, if granted, would extend protection beyond Britain into additional markets.
Giorgi Tsutskiridze, Spribe’s chief commercial officer, put the company’s position plainly in a recent interview with European Gaming: “Aviator is an internationally recognised brand and an extremely valuable piece of intellectual property. Protecting that IP isn’t optional for us. If you selectively ignore infringements, particularly significant ones, you risk weakening the brand and creating confusion for operators and players.”
The Order Has Limits, and Aviator Studio Can Fight Back
The injunction is provisional. Aviator Studio’s companies can apply to have it reviewed, and the court ruled without hearing their side, which is the nature of an ex parte order. Spribe must also commence proceedings leading to a decision on the merits within 31 calendar days of the 1 September order. That is not a technicality: if Spribe misses that window, the provisional protection lapses. The review hearing will be the first real test of whether the prima facie finding holds under adversarial argument, and Aviator Studio will almost certainly appear.
A Two-Year Legal War Across Five Continents
The Malta order sits inside a dispute that has now spread across Georgia, the UK, Curaçao, Brazil, and the EU. In August 2024, Georgia’s Court of First Instance found against Spribe, ruling that its Georgian trademarks had been registered in bad faith and had infringed Aviator LLC’s copyright, awarding Aviator LLC $330 million in damages against Spribe and Flutter-owned Adjarabet. A source at the time described the quantum of damages as egregious and bearing no relation to the actual economics of the property. Georgia’s Supreme Court upheld the ruling in May 2025.
Outside Georgia, matters have been working in favour of Spribe. An interim injunction was awarded to Spribe in July 2025 by the UK High Court against Aviator LLC preventing its competitor game in the UK. Then Deputy Judge Michael Tappin KC granted Spribe a procedural victory in May 2026 by determining that it would not simply be possible to rely upon the determinations of the Georgian courts according to English law. The Court of First Instance in Curaçao declared the two trademarks of Aviator LLC invalid on 25 May 2026, with Aviator LLC being absent after being summoned. In Brazil, the 18th Federal Civil Court of the Federal District suspended the trademark registration of Spribe’s Aviator on 16 October 2026, based on a complaint made by Aviator Studio Brazil. Aviator Studio said that the court recognised its submission about the evidence of the existence of the Aviator trademark before Spribe filed it in Brazil.
The Curaçao judgment records that Spribe has now lodged more than 120 opposition proceedings worldwide against Aviator LLC and connected entities.
Expert Analysis: The Danger of Winning Battles Before the War Is Decided
We have watched Spribe build one of the broadest IP enforcement campaigns in recent iGaming history: provisional orders, interim injunctions, trademark oppositions filed across more than 120 proceedings, court wins in Curaçao and the UK, and now an EU-wide provisional block from Malta. The legal machine is working. But a question worth sitting with is this: what does it mean when a company needs 120+ proceedings to protect a single game title?
The honest answer is that it reveals just how genuinely unsettled the underlying IP question remains. Courts in Georgia and Brazil have found against Spribe’s trademark position. Courts in the UK and Curaçao have gone the other way. The Malta order is provisional, not permanent, and requires Spribe to prove its case on the merits within a tight window. Every injunction secured so far is enforcement before verdict; the definitive ruling on who owns the Aviator identity has not arrived yet. That matters enormously for operators currently deciding which Aviator game to carry, under whose licence, and whether the supplier they signed with will still hold enforceable rights when the full UK trial concludes. In our view, the industry is watching a fight that looks decisive in each individual round, but whose final outcome remains genuinely open. That is not a comfortable position for anyone writing a distribution agreement right now.
Share
5 views
