In a sweeping ruling, the Supreme Court held that a plaintiff's significant delay in suing for copyright infringement did not bar the plaintiff from seeking damages for infringement occurring during the Copyright Act's three-year "look back" window. Petrella v. Metro Goldwyn Mayer, Inc., ___ U.S. ___ (May 19, 2014). Laches is a long-recognized equitable doctrine that precludes claims for certain relief if the plaintiff unreasonably delays in bringing suit. Although the copyright holder in Petrella waited eighteen years to sue for infringement over rights to the motion picture "Raging Bull," that delay, according to the Court, did not prevent the plaintiff from seeking damages for DVDs sold during the three years prior to institution of the suit.
While the Court's decision relates only to copyright, it may have an impact on patent cases as well. The prevailing rule in patent cases has been that unreasonable delay (presumptively, six years or more), coupled with material prejudice, completely bars claims for past damages, even for infringement occurring during the Patent Act's six-year "look back" window. The Supreme Court noted this rule, but declined to address the application of laches in the patent context. It, therefore, remains to be seen whether the Supreme Court's ruling will expand opportunities for patent infringement suits that would otherwise be limited to future damages or injunctive relief.