What is Respondent's laches defense?

Respondents' sixth affirmative defense states that the instant action [sic] is time-barred by laches. An equitable defense, laches requires the existence of four primary elements: "(1) conduct by an offending party giving rise to the situation complained of, (2) delay by the complainant asserting his or her claim for relief despite the opportunity to do so, (3) lack of knowledge or notice on the part of the offending party that the complainant would assert his or her claim for relief, and (4) injury or prejudice to the offending party in the event that relief is accorded the complainant." Dwyer v. Mazzola, 171 A.D.2d 726, 727 [2d Dept 1991]. Respondents' laches defense does not include facts articulating any of the required laches elements. Accordingly, it is wholly conclusory and must be dismissed.