| http://www.w3.org/ns/prov#value | - ircuit found that, where the fire was caused by a condition of unseaworthiness, there was an overriding obligation on the part of the carrier to prove due diligence to make the ship seaworthy before it could invoke the fire exception or the Fire Statute.[106] In trying to solve the conflict between the 1851 Fire Statute and COGSA, the Ninth Circuit realistically but improperly relied on Canadian j
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