Even though laches and unclean hands are not valid defenses to a pure claim of contract at law that is brought within the statute of limitations, such defenses may survive in a mixed case of contract and patent law, the Court held in Koninklijke Philips Elects. N.V. v. Cinram Int'l Inc., No. 08-CV-00515 (S.D.N.Y. Apr. 8, 2013) (Stearns, J.).
In denying Philips' motion for judgment on the pleadings regarding unclean hands, laches, and estoppel, the Court reserved its judgment on the defenses since the case is a mix of contract and patent law. The Court found that Philips was too late in arguing that the defendants did not adequately plead these defenses, since the case has been pending for over five years and Philips has had ample opportunity in discovery to explore the basis of defendants' affirmative defenses.
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