Extract to table

2d 157, 162 (1990) ("When the terms of a written contract are clear and unambiguous, the intent of the parties must be found within the four corners of the contract, giving a practical interpretation to the language employed and reading the contract as a whole

As a threshold matter, liquidated damages clauses are enforceable under New York law where two conditions are met: (a) the amount stipulated must be a reasonable estimate of the anticipated harm from the breach, and (b) actual damages from the breach must be difficult to calculate at the time the contract is made

Several well-established canons of New York contract interpretation support TSL's reading of Clause 28: First, courts must give effect to all terms and avoid interpretations that render any contractual language superfluous or meaningless

§ 30701 note, § 4(4) (providing that deviation in saving or attempting to save life or property at sea, or "any reasonable deviation," shall not be deemed a breach)

Even if the Maputo call were characterized as a deviation — which TSL vigorously disputes — Northwind must prove that the four-day delay directly caused the missed Qingdao laycan