ARGUMENT OF GREAT BRITAIN. 113 



tained iu the Report of tlie British Commissioners, and British c om- 

 it is then stated that the Commissioners have failed to pJrt par^. 447- 

 authenticate these. This alleged "failure" must of course ^^^^'^2;^,^^24.^^^'^^ 

 remain a matter for decision on the evidence produced, * ^^ ^^^'^' 

 but the additional information obtained in 1892 respecting 

 Haycock and other islands and rocks, with that relating to . . 

 the taking of female seals in milk ofi" various parts of theter-case.^Appeu- 

 British Columbian and Alaskan coasts to the south of the ^'|^^oi- J- pp- i35, 

 Aleutian Islands, go for to reinforce the already strong 

 body of evidence on this point adduced by the British 

 Commissioners. 



Attention is then, in the United States Counter-Case, g^fL^^^xj^x 

 directed to the statement made by the British Commis- couliter-case^ 

 sioners, on the basis of information gained by them on the ^pp*^"*^^' p- ^'^'^■ 

 Commander Islands and at Petropavlovsky, as to the for- 

 mation or attempted formation of new rookeries at various 

 places on the Asiatic coast. Mr. Malonavonski is quoted 

 as having visited one such reported rookery on the Kamts- 

 chatka coast, and as having found the animals there to be 

 sea-lions and not fur seals. Upon this single inconclusive 

 statement the following remark is made: 



If all the iucipient breeding rookeries alleged to exist on the Asiatic 

 coast were examined, doubtless they would be found to be similar to 

 the one above noted. 



Mr. Grebnitzky is cited to the effect that he thinks it to 

 be wholly improbable that the Commander Island seals 

 visit any other land, but it will be observed that though 

 the United States took i^ains to obtain a written statement ibid., p. 303. 

 from this gentleman, for the purpose of counteracting his 

 statements as quoted in the British Commissioners' Eeport, iwd., p. 362. 

 he has not iu this document contradicted his specific refer- m^"oners'^ii™i 

 ence to the formation of a new fur seal rookery on the p^rt, para. 519. 

 Kamtschatka coast. 



Tiie great importance evidently attached by the United 

 States to the denial of the evidence showing that tha fur- 

 seal on the Asiatic coasts has sought and found new 

 breeding-places, evidently depends on the circumstauce 

 that this evidence tends to substantiate the less com- 

 140 plete details respecting the existence of such breed- 

 ing-places (other than the Pribyloff Islands) on the 

 coast of I^orth America. 



On the strength of the above imperfect discussion, and 

 the inconclusive negations above outlined, it is then denied 

 on the part of the United States that the — 



Alaskan seals have any other home than the Pribyloff Islands, and 

 that, even if constantly disturbed by man while on the rookeries they 

 would seek a new habitation. 



The denial above summarized is not only contrary to all 

 natural facts, but bristles with ambiguities. If the term 

 "Alaskan seals" means only the seals breeding on the 

 Pribyloff Islands, it may readily be admitted that they have 

 no other breeding-place. If the breeding-place is the only 

 "home " of such seals, it of course follows that this " home " x 

 must be on the Pribyloff Islands. But the use made of the 

 term "home" is a purely conventional one, and thus, if the 

 territorial possession of the "home" is supposed to imply 

 B s, PT X 8 



