in the record that the skids contained 177 packages — or any other number except perhaps six — suitable for shipping on their own. Second, the cardboard sleeve enclosing the contents of the skids was more like the cardboard packaging the American & Far Eastern court distinguished than like the shrink-wrapped pallets. And third, the skids were not transparent, and the bill of lading was not ambiguous. American & Far Eastern thus does not support plaintiffs position. Furthermore, there are cases from this circuit in which it was held that where cargo was contained in parcels which in turn were packed in larger parcels, the larger parcels were the COGSA packages. In Nemeth, supra, the Ninth Circuit held that household goods packed in S.S. “Yang Ming”, 672 F.2d 1055, 1056-57 (2nd Cir.1982) (<HOLDING>). Plaintiff relies especially heavily on Sony,
holding that bill of lading issued as to two containers was binding as to third container which was stolen and as to which no bill of lading issued provided that the bill of lading in evidence was the standard form bill of lading that carrier always used holding that the parties designated the number of packages in the bill of lading when they filled in the numbers 18 103 and 165 under the column heading no of pkgs holding that 30 pallets were the cogsa packages where the bill of lading stated that there were 30 packages holding that only one offense should have been charged when four separate packages of the same drug were found holding that where bill of lading indicated 1320 cartons but did not indicate that the cartons were consolidated onto 52 pallets the 1320 cartons were the cogsa packages