Mitsui & Co. Ltd. & Ors. v. American Export Lines, Inc.; Armstrong Cork Canada & Ors. v. American Export Lines, Inc. - Chief Judge Feinberg, Circuit Judges Friendly and Oakes - U.S. Ct. of Apps. (2 Cir.) - Jan. 16, 1981

Limitation of liability - Whether container is “COGSA” package - COGSA, s.4(5)

A number of containers were lost or damaged while en route from New York to Japan. The carrier admitted liability but then sought to limit his liability to $500 per container.