My understanding, from being in the coin hobby many years ago, was always that the risk passes to the buyer when the item is shipped. The buyer (or seller) may mitigate that with insurance. Ebay or other rules aside, in the end, the buyer is on the hook if the seller can prove the item was shipped.
Even with ebay/paypal rules, if the seller can show the item was "delivered", ebay is going to side with the seller. In this case it was "delivered". I know the whole thing sucks but the buyer is probably going to be on the hook unless the seller just wants to issue a refund because he's a nice guy.
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