ORAL ARGUMENT OF CHRISTOPHER ROBINSON, Q.. 0. 303 



petent. We know you are not competent to make Eegulations on the 

 Islands, and we submit yon are not competent to make liegnlations out- 

 side Bebring- Sea — that is all I say. 



The President. — You think we cannot do good work? 



Mr. Robinson. — I do not think you can do efficient and full work — I 

 hoi)e I shall not be misunderstood in that. I do not think your powers 

 are sufficient to enable you to frame Kegulations for the efficient pro- 

 tection of the seal race. In our judgment that would require Regu- 

 lations on the Islands; in Behring Sea; and in the North Pacific Ocean. 



The President. — I am satisfied that you have stated it distinctly. 



]Mr. Robinson. — I understand — and I wis!) to have no misapprehen- 

 sion — that whenever one side or another is charged with insincerity, it 

 at least becomes them to be sincere in stating the view they take of the 

 position they assume; and I hope, Mr. President, you understand me 

 in regard to that. 



We are ]>erfectly willing to concur in the only Regulations which we 

 believe will ensure the object which both sides have at heart,and wiiich 

 ought to be carried out; but so long as on the part of the United States 

 they say : 



''We are going to enter into no such agreement — we are goiu^ to 

 allow you no voice in the place where you think some Regulations are 

 perhaps most essential." 



Then we say : 



" We shall confine you, in the Regulations you are imposing upon us, 

 to the words of the Treaty." 



Now the first consideration that comes before us is naturally, and of 

 course, the consideration of the words of the Treaty. I have heard it 

 said that if you take the words of the Treaty by themselves it is difficult 

 to argue that they do not authorize Regulations extending any where. 



Of course I am speaking altogether of clause 7. I ought to have said 

 in commencing this argument, that I think our aigument upon this 

 subject, namely uj^on the area of Regulations, is largely connected with 

 the argument as to the area of the claim of Property Rights. The 

 learned Attorney General has argued that, and you Avill find his argu- 

 ment in the Shorthand Writer's notes, pages 944 to 904. I am not going 

 to return to that, or touch upon it, more than to give the Tribunal the 

 reference to it. If that argument was not powerlul and convincing to 

 the minds of the Tribunal, it would be presumption in me to attempt 

 to strengthen it or add to it. I have no thought of doing anything of 

 the kind, but I proceed on the assumption that the learned Attorney 

 General has made out his position, that the area of the claim of rights 

 in Question 5 is limited in its extent to Behring Sea; and I propose, 

 now, to say a word about the area of Regulations. I shall have to come 

 back perhaps to one point which it may be as well to call the attention 

 of the Tribunal to at this moment. You will remember. Sir, that in the 

 Argument of the United States upon that Question 5 they take this 

 X)Osition. They say — and for the first time they say as far as we know 

 in the course of these discussions — for the first time they say in their 

 printed Argument that they are entitled to Regulations in addition to 

 protection. Y''ou no doubt understand what I mean. In the beginning, 

 and from the beginning, the claim was Rights or Regulations— in other 

 words, they have said: 



'••We claim to own these seals in Behring Sea, or to protect them in 

 Behring Sea; and we say, if we have not either this Right or the Right 

 of Protection, then you should agree with us in making some Regula- 

 tions which will supply its place." 



