Insurance Company of North America v. Nnr Aircargo Service (Usa), Inc., a Corporation, Opinion

D.W. NELSON, Circuit Judge:

Insurance Company of North America (INA), in its effort to recover for the loss of $257,285.34 in stolen golf balls, appeals the district court’s summary judgment order limiting the liability of NNR Aircargo Service (NNR) to $50. INA makes five arguments: (1) invoices are not contracts and there was no course of dealing sufficient to infer the parties’ common understanding of the agreement; (2) there was uncertainty with respect to the meaning of the limitation term, “$50 per shipment”; (3) actual possession of the invoice is required to enforce the limitation of…