KRAVITCH, Circuit Judge:
This appeal centers on what recourse, if any, an owner of goods lost at sea has against the carrier when the owner of the goods is not a named party to the bill of lading. We also address the novel issue of what cause of action is afforded under the Carriage of Goods by Sea Act, 46 U.S.C.App. § 1300-1315 (1999) ("COGSA").
I. BACKGROUND AND PROCEDURAL HISTORY
Appellants Polo Ralph Lauren, L.P. ("Polo") and its subrogated...
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