ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q, C. M. P. 429 



I turn, first, to part 2 ])iige 1. I am not going- to read the letter, but 

 1 am going to state, Sir, what it contains. It is the first announce- 

 ment from the Clievalier de Poletica to the Secretary of State of the 

 United States. It is under date of tlie 28th February 1822. In that 

 letter the expression ''North- West Coast", occurs six times. We are 

 not now on the question of a charter to a company — we are not now on 

 the question of privileges given to individuals — we are on the question 

 of international negotiations, and tliere is not less good faith between 

 nations than there is between individuals. The phrase "North-West 

 Coast" is used six times. In every instance it is used of the coast 

 extending from Behring Straits to whatever point in the south the 

 Kussian dominion went to. 



Therefore, upon the question of what " North-West Coast" meant in 

 the opening letter to the United States dealing with these negotiations, 

 "North- West Coast" has a distinct and recognized meaning. 



What about "Pacific Ocean?" "Pacific Ocean" occurs several 

 times, but 1 will call attention, if you please, Sir, to the passage on 

 page 3 near the end of the letter : 



I onght, in tlie first place, to request yon to considei", Sir, that the Russian posses- 

 sions in the Pacific Ocean extend on the North-West Coast of America from the 

 Behring Straits to the 51st degree of north latitude. 



No Eussiau minister has ever attempted to put upon this language the 

 construction my friends seek to put npon it. According to my friend, 

 Mr. Carter, the bargain which followed out this negotiation, without 

 any change of expression, is to be supi)osed to have intended a different 

 meaning to these words. When that negotiation commenced, "North- 

 West Coast " had a distinct and definite meaning for the purpose of that 

 negotiation. " Pacific Ocean" had a distinct and definite meaning for 

 the purpose of that negotiation. The two are consistent. If " North- 

 West Coast" means the iw/ere only from 60°, then " Pacific Ocean" does 

 not include Behring Sea. If " North-West Coast" does go up to Behring 

 Straits " Pacific Ocean " does include " Behring Sea ", and I am not over- 

 stating the case as you will find — in every single instance in which that 

 occurs in that letter those are the meanings of those words. 



Now that is the opening of the negotiations with the United States. 

 Now let us look at the opening of negotiation with Great Britain. 



Would you be good enough to turn back to page 1 of the first part — 

 it is the letter from Baron Nicolay to the Marquis of Londonderry. It 

 is in French, but perhaps I ought to refer to the two letters — Baron de 

 Nicolay's of the 31st October, including Ocmnt Nesselrode's of the 7th 

 October. They are at pages 1 and 3 of the first part. They are both 

 in French, but any member of the Tribunal who will kindly run his eye 

 down will be able to see the words in a moment in several places: Les 

 cotes nord-ouest de VAmerique appartenant a la Bussie ; Ics cotes nord- 

 ouest de VAmerique : La cote nord-ouest de VAmerique, dermis le detroit 

 de Beliring jusquUm Sl'^. 



Then turning over the next page you will see: 



Cette partie de V Ocean Facifique, que hordent nos possessions en Anier- 

 ique et en Asie. — 



that is, the Pacific Ocean which bounds our possessions in America and 

 in Asia. And further down in the same letter there is another reference 

 to the Pacific Ocean. 



Now this letter of the 7th October, from Count Nesselrode to Count 

 Lieven, again has many references both to the North West Coast and 

 the Pacific Ocean, and again occurs the phrase. Les possessions Russes 

 sur les cotes nord-ouest de VAmerique et nordest de VAsie. 



