ARGUMENT OF GREAT BRITAIN. 105 



informants are named, and the detailed statements of some 

 of them are iiiehided in the Appendix to the Heport. The 

 facts, ascertained in interviews with natives along the 

 coast, are given in abstract. 



On the part of Great Britain, no such impntations are 

 made respecting the basis of the migration-maps offered 

 in the Case and Counter-Case of the United States. It is 

 in fact believed that the errors occurring in the first, and 

 those which still remain in the second, editions of this 

 map are due merely to imperfect information, and a refer- 

 ence to the data upon which these maps are constructed 

 fully bears out this belief. 



How the statement can be made on this page of the 

 United States Counter-Case, that the British Commis- 

 sioners "entirely overlooked" the important fact that full- 

 grown bull seals are not found to the south of the 5Uth 

 parallel, is inexplicable. This fact was ascertained as the 

 result of their own investigations. It is clearly set forth 

 in para. 193 of tlieir Keport, and characterized there as a 

 " noteworthy and interesting fact." 



The further statement that the Commissioners do not 

 anywhere state — 



that they ever heard of a full-grown male below the 56th parallel, 

 the assumed northern limit of the winter habitat which they have 

 created, 



is broadly incorrect, as a reference to the Report will show. British com 

 As the line drawn on the new migration-chart now offered po^tT panil r72- 

 by the United States to represent the southern limit of tbe isi^- ' 

 range of full-grown males is not supported by any evidence, ^^^ ^^^' 

 it aj)pears unnecessary to follow the argument based on 



this, and on the erroneous statement just referred 

 129 to; but it may be pointed out, that even on the incor- page 102. 



rect assumption made, *. e., that full-grown bulls are 

 seldom seen south of Baranott' Island, and that the "win- 

 ter home," referred to by the British Commissioners, is 

 therefore not that of the full-grown males: 



1. That this does not assist the further assertion made 

 to depend on it that such males have no "home" but the 

 Pribyh)ff' Islands; and 



2. That whatever rights may flow from position, prox- 

 imity of territory, or food consumed by the fur-seals, may 

 be held equally on animals of either sex or any age, the 

 number being the principal consideration, particularly in 

 respect to the consumption of food fishes. 



Stress is laid in the United States Counter-Case on the Pages 102,103. 

 fact that sealing is conducted to a certain extent south- 

 ward along the isTorth American coast, as far as California, 

 and it appears to be considered that this fact invalidates 

 the migration-map printed in the British Commissioners' 

 Report. An examination of this map and of the Report British com- 

 will, however, show that it has been fully recognized, and n'i««i""erH' Re- 

 was considered and particularly mentioned by the Commis- am/ 'pMa8T''582^ 

 sioners. It was very clearly not the purpose of the Com- 596. 

 missioners in this map to indicate the whole vast region of 

 ocean which might at any time be resorted to by any fur- 

 seals, but to distinguish and make plain, as the facts 



