Jarrow Formulas, 304 F.3d at 836. There is some disagreement in the case law concerning the most closely analogous state law action for the federal claims at issue in this case. In Jarrow Formulas, a false advertising case brought under Lanham Act section 43(a) subpart (1)(B), the parties agreed, and the Ninth Circuit held, that the most analogous limitations period is California’s period for fraud, which is three years. Id. at 838. On the other hand, the Ninth Circuit’s more recent opinion in Glenn Miller held that all Lanham Act claims in general, including claims brought under Lanham Act section 43(a) in particular, are governed by the limitations period in California’s statutes for trademark infringement and dilution, which is four years. Glenn Miller, 454 F.3d at 997 n. 11, 986 (<HOLDING>). Unlike the federal Lanham Act claims asserted
holding that a laches defense is precluded under a section of the lanham act providing for cancellation at any time holding that the statute of limitations for all of plaintiffs eleven causes of action including those brought under lanham act  43a 15 usc  1125a and lanham act  43c 15 usc  1125c is four years recognizing that willful blindness is equivalent to actual knowledge under the lanham act holding that section 43a of the lanham act protects trade dress holding that reasonable anticipation standard for the tort of passing off under section 43a of the lanham act remains the law in the third circuit