130. Finally, the Court observes that, in June 1994, the IBR asked the INDI to rule on the expropriation request filed by the Community, because it considered that the administrative channel had been exhausted. However, the case file does not record whether the INDI responded to this request. To the contrary, the measures taken by the latter reveal that it sought to continue under the administrative channel, a fact that was confirmed by the INDI President at the time, who stated that “[t]his President’s actions focused on trying once more […] to conclude this administrative case by negotiation.”154 131. Based on the foregoing, the Court considers that the action filed by the Community to claim its lands was not conducted with due diligence. Consequently, the Court concludes that the actions of the State authorities have not been compatible with the standards of diligence established in Articles 8(1) and 25(1) of the American Convention. 2.2.2. Principle of reasonable time in the administrative action 132. Both the Commission and the representatives argued that the duration of the land claim action violated the principle of reasonable time. The State did not refer to this argument. 133. Article 8(1) of the Convention establishes that one of the elements of due process is that actions to determine the rights of individuals under the civil, labor, criminal or any other jurisdiction must be conducted within a reasonable time. The Court has considered four elements in order to determine whether the time is reasonable: (i) the complexity of the matter, (ii) the conduct of the authorities, (iii) the procedural activity of the interested party,155 and (iv) the effects on the legal situation on the person concerned.156 134. Regarding the first element, the Court recognizes, as it has done on previous occasions in relation to this remedy,157 that the matter in this case is complex. However, it notes that the delays in the administrative proceedings were not due to the complexity of the case, but rather to the deficient and delayed actions of the State authorities (second element). As stated previously, the activities of the State organs in charge of deciding the Community’s land claim were characterized during the whole addressed to the INDERT, file of appendices to the application, appendix 5, folio 2377, and request by the representatives on August 23, 2006, file of appendices to the application, attachment 5, folios 2379 and 2380). 153 In 2006, the representatives of the Community had to request the reconstitution of the administrative file because it been “mislaid twice” in the INDERT (Cf. Request of the representatives of the Community of July 6, 2006, supra note 152, folio 2377, and testimony of Clemente Dermott, supra note 63, folio 645). In her testimony, the current President of the INDI indicated that, in 2008, “many documents were lost, [so that] even today, the case file of the Xakmok Kasek people was being reconstituted,” because the INDI had been occupied by indigenous groups (Cf. Testimony of Lida Acuña, supra note 17). 154 Memorandum of the INDI President of August 21, 1995, supra note 119, folio 859. 155 Cf. Case of Genie Lacayo v. Nicaragua. Merits, reparations and costs. Judgment of January 29, 1997. Series C No. 30, para. 77; Case of Garibaldi v. Brazil. Preliminary objections, merits, reparations and costs. Judgment of September 23, 2009, para. 133, and Case of Radilla Pacheco v. Mexico, supra note 12, para. 244. 156 Cf. Case of Valle Jaramillo et al. v. Colombia. Merits, reparations and costs. Judgment of November 27, 2008. Series C No. 192, para. 155; Case of Garibaldi v. Brazil, supra note 155, para. 133, and Case of Radilla Pacheco v. Mexico, supra note 12, para. 244. 157 Cf. Case of the Yakye Axa Indigenous Community v. Paraguay, supra note 5, para. 87. 32