28 ARGUMENT OF GREAT BRITAIN. 



British coun- The fur-seiil is not only a marine animal, but pelagic in 

 terCase, p. 100. jjr^^jit^ Spending most of its time at large in the open ocean. 

 It is migratory in its habit, and in the course of the year 

 traverses a great part of the North Pacific Ocean. 



Tlie time in each year during whicli various classes of fur- 

 seals (or some considerable portion of them) remain on or 

 about the breeding-islands for purposes of reproduction, is 

 from three to live and ahalf months. But individual seals 

 (with the exception of the old bulls) frequent the a<ljacent 

 "waters for much of the time of their resort to the islands, 

 and many young males and virgin females luobably do not 

 land at all. Tlie average length of stay ashore of the seals 

 is about one-tliird of the year. 

 Ibid., p. 101. The food of the fur-seal is entirely derived from the sea. 

 Ibid., p. 142. The expression "home" or "sole home," applied to the 

 Pribyloff Islands in connection with the fur-seals found in 

 the eastern part of the Pacific, is inadmissible, even on the 

 assumj)tion that all are born there. A migratory animal 

 cannot be said to be "at home" only when in its breeding- 

 area. The home of any species is the area within which it 

 habitually lives. Animals may have winter as well as 

 summer homes. 



The principal "winter home" of the fur-seals of the 

 eastern part of the North Pacific is the part of the ocean 

 lying off the coast of Ihitish Columbia; and there enor- 

 mous quantities of fish, which would otherwise be available 

 for the support of the inhabitants, are consumed by the 



seals. 

 29 The principal "winter home" of the fur-seals of 



the western part of the North Pacific, is, similarly, 

 in the vicinity of the Japanese coasts. But seals in 

 smaller numbers are to be found in all parts of the North 

 Pacific. 

 British Coun- In the summcr months, most of the seals go northwards 

 ter-case, p. 142. ^^^ breeding purposes. Some go to the Commander Islands, 

 others to the Kurile Islands and Robben Island, others to 

 the Pribyloff" Islands. 



No special bodies of the seals can be said to resort entirely 

 and invariably to one or other of these groups of islands. 



Intermingling occurs between the seals of the North 

 Pacific generally, both to the north and to the south of the 

 Aleutian Islands. 



The allegation that the identity of individual seals can 

 be established when at sea cannot seriously be advanced. 

 ibid.,p.i36. Experiments and observation further sliow that seals 

 born on one of the Pribyloff Islands often land in another 

 year on the other island, and that the relative numbers of 

 seals on the two islands varies from year to year. 



The tendency of the slaughter carried on upon the Priby- 

 loff' Islands is to drive the seals away from these islands, 

 and many other islands are available as breeding-places. 

 ibid.,p.i4i. The fact of the intermingling of the seals of both sides 

 of the North Pacific, likewise shows that not all the seals 

 found in the eastern part of that ocean can have been born 

 on the Pribyloff Islands. 

 ibid.,p.ii9. The expression "Alaskan herd" is simply a fanciful 

 creation, supposed to lend, by the use of the term " herd," 



