Sony Corp. packed a shipment of videocassette tapes into a 40-foot ocean container for transport to England. Sony put the tapes into 1,320 cardboard cartons, then strapped the cartons onto 52 wooden pallets. The pallets were put into one shipment container. The bill of lading stated "1 40 ft. container: 1,320 ctns. magnetic tape." The value of the tapes shown on the export certificate was $400,000. On loading, the ship's deck crane dropped the container 60 feet to a concrete deck. Sony claims it can recover the value of the tapes. The ship maintains that under COGSA its liability is limited to 52 pallets. How many "packages" were involved here and what do you think should be the outcome? Sony Magnetic Products Inc. of America v. Merivienti O/Y, 863 F.2d 1537 (11th Cir. 1989).