NAACP v. NAACP Legal Def. & Educ. Fund, Inc. - 243 U.S. App. D.C. 313, 753 F.2d 131 (1985)

Rule:

The essential elements of laches are well-defined by common law. There are three affirmative requirements: (1) a substantial delay by a plaintiff prior to filing suit; (2) a plaintiff's awareness that the disputed trademark was being infringed; and (3) a reliance interest resulting from the defendant's continued development of good-will during this period of delay. Courts also look for factors that may negate the invocation of laches by excusing the delay: (1) ongoing negotiations; and (2) conscious fraud or bad faith by the defendant. 

Facts:

Plaintiff, the National Association for the Advancement of Colored People (NAACP), founded the NAACP Legal Defense Fund (LDF), defendant, in 1939. After several decades of working together, the two organizations split but retained their names. Due to growing tension between the two organizations, plaintiff demanded that defendant drop "NAACP" from its name. LDF refused, and 13 years later, NAACP brought an action for an injunction to prevent LDF from using the name "NAACP". The trial court found for NAACP and LDF appealed. On appeal, LDF argued that laches prevented NAACP from obtaining the injunction.

Issue:

Did the district court err in denying the LDF's defense of laches?

Answer:

Yes

Conclusion:

The court found that NAACP satisfied the requirements for the defense of laches because they took no action for 13 years, NAACP had knowledge that LDF was using "NAACP" in their name, and NAACP’s delay allowed LDF to justifiably rely that no action would be taken. Consequently, the judgment for NAACP was reversed.