ARGUMENT OF GREAT BRITAIN. 21 



Article YI dealt only with the lisiere, granting to Great 

 Britain a perpetual right of navigation of all the rivers 

 flowing to the Pacilic across the line of demarcation of the 



Z/skVe indicated in Article III. 

 21 Article VII, on the other hand, dealt with the coast 



of the continent, mentioned in Article III : it gave 

 to the two parties a reciprocal right of visit to all the inland 

 waters, harbours, «S:c., on this coast: it applied, therefore, 

 to the coast of the whole of the liussian possessions, as 

 well as to the whole of the coast of the British possessions. 



If the right of access under Article VII were limited to 

 the coast of the lisiere, the reciprocal character of the 

 Article would be destroyed. 



The text of the Treaty clearly shows, therefore, that the 

 expression " north-west coast" included the whole of the 

 coast on the north-west of the American continent; and 

 that the term "Pacific Ocean" included all the waters 

 washing the north-west coast, including Behring Sea. 



This argument is supi:)orted bv the fact that in the Trea- i^n'tish cmm 

 ties of 1811, 1843, and 1859, concluded by Kussia with Great ^'''■^''^^' P' ^i- 

 Britain and other Powers (and which are examined in the 

 British Counter-Case, pp. 51-52), the term "North-west 

 coast of America" is used in a manner showing conclusively 

 that it included the coast of Behring Sea. 



The Treaty of 1859 did not expire till 1869, i. e., after the 

 cession of Alaska to the United States. 



The notice issued by the United States in 1845 at the 

 request of Russia warns the United States citizens against 

 infringing the Treaty of 1824 by "resorting to any point 

 upon the Russian- American coast where there is a liussian 

 establishment." This notice clearly applied to all the coast 

 of Behring- Sea. 



The Cession of Alaska to United States in 1867. 



The whole of the Russian territories on the north-west 

 coast of America, together with the islands, were ceded by 

 Russia to the United States Treaty of 1867. 



UNITED STATES STATUTES, &C., DEALING WITH ALASKA. 



It is submitted that the United States official Acts and 

 Statutes dealing with Alaska Territory next mentioned^ 

 whatevertheir construction, have no forceor validity against 

 foreigners, and therefore afford no support to the position 

 assumed by the United States. They are as follows: 



The Act of July 1868, section 1, extending the laws Tinited states 

 22 of the United States relating to customs, commerce, ^''''*'"^' ^' ^^' 



and navigation over all the mainland, islands, and 

 waters of the territory ceded to the United States by Russia. 



Section 1956, Revised Statutes, Chapter 3, title 23, pro- n,;,!., Appen- 

 hibiting the killing of fur-seals and other animals within ^ix, vol. i.p-se. 

 the limit of Alaska Territory, or in the waters thereof. 



"An Act to provide for the protection of the Salmon iwd., p. 99. 

 Fisheries of Alaska, 1889," section 3, declaring that Sec- 

 tion 1956, above, shall "include and apply to all the domin- 



