69 166. Consequently, it is primarily the responsibility of the national judicial authorities to ensure that the duration of the pretrial detention does not exceed a 235 reasonable time. That time cannot be established in abstract terms because it 236 responds to criteria whose impact should be determined in each individual case. Thus, it falls to the State to present elements to justify extending the duration of the 237 measure. 167. The European Court has ruled that an extension of pretrial detention 238 should be based on relevant and sufficient reasons to justify its prolongation, and that in cases in which it is extended significantly, that justification should be “particularly convincing” and demonstrate the continued existence of the grounds that 239 originally justified its enforcement. 168. In determining the reasonableness of that duration, although attention can be paid to such elements as the complexity of the case and the diligence of the judicial authorities in pursuing the investigations – elements that should also be used to analyze the total duration of the proceedings (within the scope of Article 8.1 of the Convention) – in examining the duration of pretrial detention, the evaluation of those factors should be much stricter and more constrained on account of the denial of 240 liberty it entails. 169. In particular, the complexity of the case should be analyzed based on the facts and the difficulty entailed in proving them. As a counterpart, the diligence of 235 ECHR, Case of Sardinas Albo v. Italy (Application No. 56271/00), Judgment of February 17, 2005 (First Section of the Court), para. 85; ECHR, Case of Labita v. Italy (Application No. 26772/95), Judgment of April 6, 2000 (Grand Chamber), para. 152; ECHR, Case of Letellier v. France (Application 12369/86), Judgment of June 26, 1991 (Plenary of the Court), para. 35. 236 IACHR, Application from the Inter-American Commission on Human Rights to the Inter-American Court of Human Rights against the Bolivarian Republic of Venezuela in Case 11.663, Oscar Barreto Leiva, October 31, 2008, para. 136; IACHR, Report No. 86/09, Case 12.553, Merits, Jorge, José, and Dante Peirano Basso, Uruguay, August 6, 2009, para. 135 (in accordance with the constant jurisprudence of the European Court). See also ECHR, Case of Lukovic v. Serbia (Application No. 43808/07), Judgment of March 26, 2013 (Second Section of the Court), para. 46; ECHR, Case of Piruzyan v. Armenia (Application No. 33376/07), Judgment of June 26, 2012 (Third Section of the Court), para. 94; ECHR, Case of Sardinas Albo v. Italy (Application No. 56271/00), Judgment of February 17, 2005 (First Section of the Court), para. 84; ECHR, Case of Labita v. Italy (Application No. 26772/95), Judgment of April 6, 2000 (Grand Chamber), para. 152; ECHR, Case of W v. Switzerland (Application No. 14379/88), Judgment of January 26, 1993 (Grand Chamber), para. 30. 237 IACHR, Report No. 66/01, Case 11.992, Merits, Dayra María Levoyer Jiménez, Ecuador, June 14, 2001, para. 48. 238 ECHR, Case of Melnikova v. Russia (Application No. 24552/02), Judgment of January 30, 2008 (First Section of the Court), paras. 83 and 84. 239 ECHR, Case of I.A. v. France (Application 28213/95), Judgment of September 23, 1998 (Grand Chamber), para. 111. 240 IACHR, Report No. 86/09, Case 12.553, Merits, Jorge, José, and Dante Peirano Basso, Uruguay, August 6, 2009, paras. 127 and 128; IACHR, Report No. 12/96, Case 11.245, Merits, Jorge A. Giménez, Argentina, March 1, 1996, para. 111.