ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 129 



in the sense in which it was used in the Treaties, referred only and 

 strictly to the lisiire, as ultimately defined in the Treaty of 1825. Now 

 having stated that correctly as my learned friend's contention, I do not 

 stop to point out, though I may have to do it later, that my learned 

 fiiend has given one of four different interpretations which have been 

 advanced by the United States as to the meaning of that phrase "north- 

 west coast". It will be convenient for me here to mention what those 

 four inter]»retatious were. I will not stop to justify this assertion now ; 

 but I think it will be apparent when I come to read the correspondence. 



Mr. Carter. — I referred to the limitation of the words "northwest 

 coast" as used in the Ukase. 

 874 Sir Charles Eussell. — Very well; I am obliged to my 



learned friend for correcting me; as used in the Ukase, it was 

 much more. 



Mr. Carter. — I did not say that. 



Sir Charles Russell. — If it was not confined to the Usierey it 

 extended beyond it, and, therefore, meant more than the lisiire. 



Mr. Caarer. — I only spoke of what my argument was. 



Sir Charles Kussell. — I now i^oiut out what these four construc- 

 tions were. In the despatch to Sir Julian Pauncefote of the 30th of 

 June, 1890, Mr. Blaine examined the Treaties of 1824 and 1825, and says 

 it is plain that they both limited the "northwest coast" to the coast 

 between the 50th and 60th degrees of North latitude. 



[Sir Richard Webster then pointed it out on the map.] 



On the 17th of December, 1890, he again writes, and discusses the 

 meaning of "Pacific Ocean" and "the Northwest coast"; and he 

 observes in that letter that the dispute as to the meaning of "Pacific 

 Ocean" prominently involves the meaning of "the Northwest coast"; 

 and, in that letter he contends that "the Northwest coast" means the 

 coast from the 42nd to the 60th degrees of North latitude. 



[Sir Richard Webster then pointed it out on the map.] 



I observe, in passing, that neither of those contentions has been 

 thought worth inserting in the United States Case or Counter-Case. 



A third construction suggested is that it is identical with the lisiere. 



The fourth construction is put forward in the United States Case at 

 page 26, where they say that the term "Northwest coast" is intended 

 to designate the coast between Prince William's Sound and the mouth 

 of the Columbia River. 



[Sir Richard Webster then pointed it out on the map^] 



Those four meanings have been given by the United States to that 

 phrase "Northwest coast". 



Now, I will ask the attention of the Tribunal to what it really means. 



I agree fully with Mr. Blaine that the two phrases "Northwest 

 coast" and "Pacific Ocean" have a very important bearing indeed on 

 the question whether Behring Sea was not included in the phrase 

 "Pacific Ocean". First of all, of course, it is important to see, inas- 

 much as the Treaties of 1824 and 1825 were the result of the protests, 

 up to a certain point joint, and after that separate, of the United States 

 and of Great Britain it is important, of course, to see what was the 

 assertion, on the part of Russia, of jurisdiction against which these 

 protests were jointly and severally made. I turn to the Ukase. 



It is set out on page 16 of volume I of the Appendix to the United 

 States Case. 



Rules established for the limits of navigation and order of communication along 

 the coast of Eastern Siberia, the Northwest Coast of America, and the Aleutian, 

 Kurile and other islands. 



B S, PT YTTT 9 



