COGSA and Fire Statute: Vessel owner bears the burden of proving that it personally exercised due diligence to make its ship seaworthy to escape liability for a fire caused by an unseaworthy condition. Nissan Fire & Marine Insurance Co., Ltd. v. M/V Hyundai Explorer, 93 F.3d 641, 1996 A.M.C. 2409 (9th Cir. 1996)
Liability of a Vessel Classification Society Cannot be Based on Warranty of Seaworthiness. Great American Ins. Co. v. Bureau Veritas, 338 F. Supp. 999 (S.D.N.Y. 1972)