The only issue is the amount of the awards. 1300 et seq. These changes prompted the convening of a diplomatic conference in 1968 which adopted a Protocol amending several provisions of the Hague Rules. Both Belgium and the United Kingdom, however, employ the higher limitation set out in the 1979 Protocol. The difference in liability schemes is significant.
Appellants contend that the district court made a number of errors.
Wallenius concedes that the DFRs are not documents of title, a concession compelled by the disclaimers appearing on the face of the documents. There is ample authority, however, for the proposition that all bills of lading are documents of title. An argument that, although a DFR is not a document of title, it is at the same time the functional equivalent of a non- negotiable bill of lading, which is by definition a document of title, is somewhat of an oxymoron. Provided , That such maximum shall not be less than the figure above named. In no event shall the carrier be liable for more than the amount of damage actually sustained.