## Facts

- The National Association for the Advancement of Colored People (NAACP) was founded in 1909 and became widely known by the initials “NAACP.”
- In the late 1930s, NAACP created a separate litigation-financing entity, later incorporated in 1939 as the NAACP Legal Defense and Educational Fund, Inc. (LDF).
- In 1939, NAACP expressly authorized LDF to use “NAACP” in its name; LDF continuously used the initials thereafter.
- In 1957, to preserve LDF’s tax-exempt status, the organizations separated formally, but agreed LDF would continue to use “NAACP” in its name.
- By 1965, NAACP concluded LDF’s continued use created problems (including fundraising confusion), voted to demand that LDF stop using “NAACP,” and contemplated an injunction; LDF refused.
- From approximately 1966 to 1978, NAACP took no legal action; during that time LDF continued prominent use of “NAACP,” added a disclaimer of any present organizational relationship, and invested substantial resources in goodwill associated with the initials.
- In 1979, NAACP purported to rescind prior authorization; in 1982 it registered “NAACP” as a federal trademark and sued LDF for infringement, seeking to enjoin LDF’s use.

## Issues

1. Whether NAACP’s trademark-infringement action to enjoin LDF’s use of “NAACP” was barred by laches due to NAACP’s long delay after knowledge of LDF’s use and resulting prejudice to LDF.

## Decision

- The D.C. Circuit reversed the district court’s summary judgment for NAACP.
- The court held NAACP’s claim was barred by laches.
- The case was remanded with instructions to dismiss the suit.

## Legal Principles

- Laches may bar injunctive relief in trademark cases when the plaintiff had knowledge of the challenged use, unreasonably delayed enforcing its rights, and the defendant suffered prejudice from the delay.
- A plaintiff’s earlier awareness and threats of enforcement can start the relevant delay period even if the plaintiff later rescinds permission or later registers the mark.
- Prejudice is shown where, during the plaintiff’s inaction, the defendant in good faith builds substantial goodwill and invests resources in continued use of the challenged designation, making a later injunction inequitable.

## Conclusion

Because NAACP knew of LDF’s use, delayed for years without adequate justification, and LDF relied on that inaction to build substantial goodwill while acting in good faith, equity barred NAACP’s trademark suit under laches and required dismissal.


Nat’l Ass’n for the Advancement of Colored People v. NAACP Legal Def. & Educ. Fund, Inc., 753 F.2d 131 (D.C. Cir. 1985)