The plaintiff had sued a New York reinsurer of a Mexican corporation that was primarily insured in Mexico, which is where the "injury" had occurred when a tugboat owned by the company was lost in a fire.
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In the period between 1923 and 1944, the American Law Institute published Restatements of Agency, Conflict of Laws, Contracts, Judgments, Property, Restitution, Security, Torts, and Trusts.