ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. Ill 



evidence now before the Court, and a rough idea of what they thought 

 to be the comparatively speaking dense area. 



But, Mr. President, of course, we must detine terms before we use 

 them, and it is quite evident from reading the Keport that the United 

 States authorities when they si)L'ak of these 20 miles about the islands 

 characterized by, very numerous seals so numerous they could not be 

 counted, were not speaking of the same kind of distribution as that 

 which extends all over the thicker part of the British Commissioners' 

 colour. That appears from the British Commissioners' Report itself. 



Now, it may be said that I do not correctly interpret the United 

 States Map; and, therefore, I should like to read one passage of very 

 great significance from the United States evidence iu regard to this 

 uuitter. Will you. Sir, be good enough to take the United States 

 Counter Case, and let me read you a passage on page 235! What I 

 have been trying to give the Tribunal, in the hopes of assisting them, 

 is the effect of reading and boiling down these logs, reports and 

 affidavits and to give it to you as shortly as possible; but there is one 

 passage on page 235, which is deserving of special notice. Cap. 

 Coulson was iu charge of, I think, the " Eush " and he took his instruc- 

 tions from the " Albatros ", and I may tell you, Mr. President that 

 he cruized from South-south-east to North-north-east, that is to say, 

 to the eastward of the Pribilof Islands principally. He says : 



At every stcation where the vessel was stopped, codfish was taken; in some 

 localities they were abuiulaut, at others only a few were caught. 



During the month and while prosecuting the work, the vessel has cruised nearly 

 three thousand mileg, and in the whole time not one vessel engaged in taking seals 

 has been seen. The weather, as will be noticed by the Seal Log, has been unfavor- 

 able for sealing a greater jjart of the time, added to this the scarcity of seals on the 

 Eastern side of the Pribilof Islands will account for the small number of seals 

 observed or taken and the little information gathered. 



On nearly every point of the compass on which the lines were run and the seal 

 herd, or what might be termed numerous seals, were passed at ten miles. 



that means ten miles from the islands, 



And the numbers decreased rapidly, so that at forty miles few seals were seen, and 

 at fifty, on most all of the courses, no signs of seals were seen. The exception to 

 this rule was in one or two of the Northern aud North Eastern lines, where seals 

 were met in small numbers, one hundred miles away from St. Paul Island; these 

 were apparently feeding on some surface food, as large flocks of whale birds, and in 

 one instance a whale, were in the vicinity. Night coming on prevented cloSe obser- 

 vation or investigation. 



Therefore, that would show you that, at any rate speaking of the 

 eastern side, the view which I have been expressing to the Tribunal 

 was in substance the conclusion at which Captain Coulson arrived as 

 the result of his investigation. Captain Hooper's affidavit 1 have 

 already read and criticised; I will only remind you of it, on page 21(3, 

 where he says that he found, what he calls, numerous seals iu certain 

 latitudes at a distance of 300 miles, from which, — 



I infer that the western limit of the range of the Pribilof herd of seals is between 

 two and three hundred miles from the Islands. 



I criticised that when addressing you on the question of property, 

 and will not refer to it any further at present. 



Mr. Phelps. — The figure 300 is a typographical error, and should 

 be 200. 



Sir EiCHAED Webster.— Is it 200 in the original Keport? 



Mr. Phelps. — General Foster can explain it to you. 



General Foster,— 1 gave Mr. Tupper notice of the fact that we 

 would claim that that was an error, that it should be 200 in place of 



