Unless there is provision in the contract or, probably1, a custom of the particular trade to the contrary2, nothing short of an actual insurance policy is a good tender under a cif contract3. For example, no broker's cover note, nor certificate of insurance, nor other document which does not include all the terms of the usual contract of insurance, is good tender under the ordinary cif contract4. If, as is often the case, the shipper makes use of a floating policy of insurance5 or an open cover instead of a policy to insure the particular goods, it is doubtful whether, in
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