226 ARGUMENT OF THE UNITED STATES. 



on the weather experienced, that the figures representing the catch 

 compared to the boats or whole number of men employed constitute a 

 more trustworthy criterion than any general statements. l 



We may, therefore, safely say that if conjecture, based upon any rule 

 of averages, is to be resorted to for the purpose of attempting to ap- 

 proximate the probable catches of these vessels, the British Commis- 

 sioners have given far more reliable data than that furnished by these 

 claimants. 



The fallacy of these "estimates" is also shown in another way. We 

 open the schedule of the British claims at random and take the claim 

 growing out of the seizure of the Minnie, No. 19. 2 It seems, from the 

 declaration accompanying the claim, that she left Victoria the fore part 

 of May on a sealing voyage in the North Pacific Ocean and Bering 

 Sea. She entered Bering Sea on the 27th of June, at which time she 

 had caught 150 seals. She hunted seals in the Bering Sea until July 

 15, during which time she had taken 270 skins, which was at the rate 

 of 15 skins per day. She was seized on the 15th of July; leaving her 

 16 days of July and 10 in August, making 32 days in all of her sealing 

 season, during which time she would have caught, at the rate of 15 per 

 day, 480 seals; to which adding the 420 she had taken previously, 

 makes a total catch for the sealing season of 900; while her "estima- 

 ted catch" is 2,500 seals for the season. 



Take also the claim of the Ada, No. 10. 3 She entered Bering Sea, 

 as is shown by the declaration accompanying the claim, about the lGth 

 day of July, 1S87, and continued sealing in the said sea until the 25th 

 day of August, which was beyond the time when skins taken are con- 

 sidered merchantable, 4 and within two weeks of the time when, as the 

 British Commissioners admit, 5 the sealing season closes, and yet her 

 entire catch up to that time was only 1S7G skins, while the "estimated" 

 or "probable catch" is put at 2S7G. 



The value and tonnage of these vessels is also largely overstated, as 

 is shown by the tables submitted with the Counter Case of the United 

 States, 6 and the value of several of the vessels seized was ascertained 

 by sworn appraisers of Hie District Court of Alaska and shown to be 

 much lower th an th e value stated in this schedule of claims. 7 That these 



Report of Br. Com., p. 73, sec. 407. 



2 Case of Her Majesty's Coverument, Schedule of Claims, p. 56. 



3 Ibid, p. 34. 



4 Counter Case of the United Slates, Appendix, pp. 357, 376, 384. 

 6 Report of Br. Com., sec 212. 



6 Counter Case of the United states, Appendix, pp. 339, et seq. 

 » Ibid., pp. 329 38. 



