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



quote nothing' which depends upon what I may call doubtful British 

 testimony. What I am about to quote comes from Kussian sources, in 

 so far as Bancroft, among others may be said to be a iiussian source. 

 I will call your attention, Mr. President, to page 23, speaking of the 

 period just before 1799: 



Thus, on every side, rival estabiisliinents and traders were draining the country of 

 the vahiable staple upon which rested the very existence of the scheme of coloniza- 

 tion. To the east and north there were Russians, but to the south-east the ships of 

 Englishmen, Americans, and Frenchmen were already traversing the tortuous chan- 

 nels of the Alexander Archipelago, reaping rich harvests of sea-otter skins, in the 

 A^ery region where Baranoff liad decided to extend Russian dominion in connection 

 with Comj)any sway. 



Lord Hannen. — What is the Alexander Archipelago? 



Sir Richard Webster. — The Alexander Archipelago is that which 

 is in the right of the Alaska Coast, practically down the lisiere. It is 

 that cluster of islands. It is on that part of the coast which Mr. Carter 

 calls the I^orth-West Coast. 



Lord Hannen. — That was the name of it? 



Sir Richard Webster. — I think it was only the temporary name. 

 I am not sure that it has been continued since. 



Now, Mr. President, you will find — and the Tribunal will forgive me 

 if I attempt to pass this somewhat shortly — that there was a Russian 

 committee directed to sit upon this matter; that they reported, as 

 stated on page 24, with reference to the i)etition of the right to monoj)- 

 olize; and that the Ukase of 1799 was in consequence of a Russian rep- 

 resentation that the Company as it was then constituted could not 

 compete successfully with other trade competitors; and I want to know^ 

 what answer, Mr. President, is to be given to the United States view 

 of this in the state papers in the j^ear 1824, an extract from which is set 

 out on page 28. To-day the United States people say the Ukase of 

 1799 was intended to operate against foreigners. What did they say 

 in the year 1824? I call the attention of the Tribunal to page 28: 



The confusion prevailing in Europe in 1799 permitted Russia (who alone seems to 

 have kept her attention fixed upon this interest during that period) to take a decided 

 step towards the monopoly of this trade, by the Ukase of that date, which trespassed 

 upon the acknowledged rights of Spain; but at that moment the Emperor Paul had 

 declared war against that country as being an ally of France. This Ukase, which is, 

 in its form, an act purely domestic, was never notified to any foreign State with 

 injunction to respect its provisions. Accordingly, it appears to have been passed 

 over unobserved by foreign Powers, and it remained without execution in so far as 

 it militated against their rights. 



I appeal from the United States of 1892 to the United States of 1824; 

 I appeal from the period of comparative ignorance to the time when 

 knowledge must have been fresh, information easily to be acquired, 

 and facts easy to be ascertained. And the official Minister of the 

 United States in 1824 states that the operation of the Ukase of 1799 

 was purely domestic. The counsel for "the United States to-day, being- 

 desirous of proving an assertion and exercise by Russia, state formally 

 in their case that after the Ukase of 1799 foreign ships were not allowed 

 to enter Behring Sea, and they further state that it was intended to 

 operate against foreigners. Is it not saying too much; and I respect- 

 fully challenge my friend Mr. Phelps when he comes to reply — my 

 assertion is worth nothing unless I support it by reference to docu- 

 ments — to point to any act done by Russia; to point to any exclusion 

 of foreign shi]3S at any time — anything, which is in support of this alle- 

 gation. 



