80 7.1.6. Reasonable period of time 288. Article 8.1 of the American Convention establishes that one of the elements of due process of law is that courts must decide the cases submitted to their cognizance within a reasonable period of time. In this regard, a prolonged delay may be viewed, in itself, as a violation of the right to a fair trial,389 as a result of which the State must indicate and substantiate the reason for which it has required more time than is reasonable to issue a final judgment in a particular case.390 289. In that regard, a reasonable period of time must calculated on the basis of the total duration of the criminal proceedings.391 According to the terms of Article 8.1 of the American Convention, the Commission shall take into consideration, in the light of the concrete circumstances of the case, three elements that the Court has used in its jurisprudence, namely: i) the complexity of the case; ii) the proceedings activities of the interested party; iii) the conduct of the judicial authorities; and iv) matters affecting the legal situation of the person involved in the proceedings.392 290. As for the complexity of the case, the State alleged that there was delay in the proceedings because there were various events that involved many persons. The State of Colombia, however, did not claim how said features of the case had led to delays in the proceedings. 291. The Commission deems that, as indicated by the Court, the delay in conducting the investigation cannot be justified by claiming the case was complex when i) the alleged authors were individualized; ii) there are witnesses; and iii) and there are possible lines of investigation.393 In any case, so that an argument substantiating complexity can be viewed as admissible, the State must submit specific information establishing a linkage between its complexity and the delay in the proceedings. In the present case, the Commission has already proven that there were long periods of inertia, which is not consistent with the State’s claim that the case was complex. 292. As for the participation of interested parties, the Commission observes that the next of kin and witnesses have actively contributed to the case by making statements in the proceedings. Likewise, their legal representatives were appointed as civil parties to the proceedings, and therefore they ensured follow-up and promotion of the investigation, complaining on repeated occasions about the delay in processing the proceedings, as well as long periods of inertia in the proceedings. 389 I/A Court H.R., Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, paragraph 166; Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, paragraph 85; and I/A Court H.R., Case of the Moiwana Community v. Suriname. Judgment of June 15, 2005. Series C No. 124, paragraph 160. 390 I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, paragraph 142. 391 I/A Court H.R., Case of López Álvarez v. Honduras. Judgment of February 1, 2006. Series C No. 141, paragraph 129; I/A Court H.R., Case of Acosta Calderón v. Ecuador. Judgment of June 24, 2005. Series C No. 129, paragraph 104; and I/A Court H.R., Case of Tibi v. Ecuador. Judgment of September 7, 2004. Series C No. 114, paragraph 168; IACHR, Report No. 77/02, Case of 11.506, Merits, Waldemar Gerónimo Pinheiro and José Víctor dos Santos v. Paraguay, December 27, 2002, paragraph 76. 392 I/A Court H.R., Case of the Santo Domingo Massacre v. Colombia. Preliminary Objections, Merits and Reparations. Judgment of November 30, 2012 . Series C No. 259, paragraph 164. 393 I/A Court H.R., Case of the Barrios Family v. Venezuela. Merits, Reparations and Costs. Judgment of November 24, 2011. Series C No. 237, paragraph 275.