American & Far East Trading Co. v. Sea-Land Service, Inc. - U.S. District Court (N. District of California) - Judge Schwarzer - July 8, 1980

Package limitation - Cartons attached to a pallet covered by plastic “Shrink Wrapping” do not become a single package

Prior to 1977 the plaintiff shipper had delivered cardboard cartons of cosmetics to the carrier for shipment in containers from W. Coast U.S.A. to Korea, but at the beginning of that year, with new technology, the cardboard cartons were placed on pallets and the entire pallet covered with a 6 mm. polythene bag which was then passed through a heat tunnel so that the polythene bag would shrink into a tight wrapping around the pallet. It was agreed that the “shrink wrap” was a substitute for steel straps which were formerly used to hold cargo fast to the pallets.