lifted.” On this evidence, a rational trier of fact could conclude that Southwest’s conduct constituted an extreme departure from the standard of reasonable care. Because Royal raised a triable issue of fact with as to whether Southwest was grossly negligent, we must determine whether the limitation provisions in these contracts exclude liability for such negligence. Some policy considerations weigh against excluding gross negligence from an exculpatory clause. The Supreme Court has held that the common law tradition of distinguishing degrees of care produces “inconsistent and diverse results” and is “foreign to [admiralty law’s] traditions of simplicity and practicality.” Kermarec v. Compagnie Generate Transatlantique, 358 U.S. 625, 631-32 & n. 10, 79 S.Ct. 406, 3 L.Ed.2d 550 (1959) (<HOLDING>). Differentiating simple negligence from gross
recognizing duty of care owed by business invitor to invitee holding that bjecause plaintiff was an invitee the applicable standard of care obligated appellees to discover and warn or protect  against unreasonable risk of harm recognizing the general rule that a premises owner owes a licensee not only a duty to abstain from willfully or wantonly injuring the licensee but also a duty to avoid negligently injuring the licensee after the premises owner discovers that the licensee is in danger holding that ship owners have a duty of exercising reasonable care to protect passengers regardless of status as invitee or licensee holding that premises owner owed higher duty of reasonable care to visitor instead of lower duty to licensee where owners affirmative conduct of running with a pan of hot grease created a risk to a visiting child