New Headache for Trademark Litigants? Fourth Circuit’s Bayer Decision Rejects Application of State Statute of Limitations to Laches Defense

The Fourth Circuit recently held that the U.S. District Court for the Eastern District of Virginia erred in its analysis of a defendant’s laches defense against an unfair competition claim under Section 43(a) of the Lanham Act. The district court held that the plaintiff’s Lanham Act claim was time-barred under the “most analogous” state law, which the district court found to be a four-year or three-year statute of limitations under California’s fraud, unfair competition, and trademark...
By: Arent Fox

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