“However, federal courts and New York courts follow different rules for what constitutes proof of conversion. Absent some affirmative proof of conversion, courts applying federal common law will enforce a contractual limitation of liability provision.” Baloise Ins. Co. Ltd. v. United Airlines, 723 F.Supp. 195, 198 (S.D.N.Y. 1989). Federal common law governs a carrier’s liability for the loss of goods during interstate shipment. Id.

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