70 ARGUMENT OF THE UNITED STATES. 



The first step, therefore, in the further progress of our argument 

 must be to assemble more precisely and fully our information concern- 

 ing the utility of these animals, their nature and habits, the modes by 

 which they are pursued and captured, the danger of extermination to 

 which they are exposed, from what modes of capture that danger arises, 

 whether it is capable of being averted, and by what means. We pro- 

 ceed, therefore, to place before the learned Arbitrators a concise state- 

 ment of the facts bearing upon these points. 



And first, concerning their utility. That they belong to the class of 

 useful animals is, of course, a conceded fact; but in this general admis- 

 sion the extent of the utility, the magnitude of the blessiug which they 

 bring to man, may not be adequately estimated. They are useful for 

 food, and constitute a considerable part of the provision for this pur- 

 pose which is available to many of the native tribes of Indians /ho 

 inhabit the coasts along which their migrations extend. They are ab- 

 solutely necessary for this purpose to the small native population of the 

 Pribilof Islands. These could not subsist if this provision were lost. 

 They are useful for the oil which they afford; but their principal utility 

 consists in their skins, which afford clothing, not only to the native 

 tribes above mentioned, but, when prepared by the skill which is now 

 employed upon them, furnish a garment almost unequaled for its com- 

 fort, durability, and beauty. There is, indeed, no part of blie animal 

 which does not subserve some human want. The eagerness with which 

 it is sought, and the high price which the skins command in the mar- 

 kets of the world, are further proof of its exceeding utility. Its prodi- 

 gious numbers, even after the havoc which has been wrought by the re- 

 lentless war made upon it by man, exhibit the magnitude of the value 

 of the species; and if we add to these numbers, as we justly may, the 

 increase which would come if its former places of resort, which have 

 been laid waste by destructive pursuit, should be again, by careful and 

 protected cultivation, repeopled, the annual supply would exceed the 

 present yield perhaps tenfold. 



Leaving out of view here the unlawful character of the employment, 

 we may say that there is a further utility in the employment given to 

 human labor in the pursuit and capture of the animal and the manu- 

 facture of the skins. There are probably two thousand persons em- 

 ployed for a large part of the year in the taking of seals at sea, and a 

 large number in the budding of the vessels and making of the imple- 

 ments required in that occupation. A much larger number, principally 



