232 ARGUMENT OF THE UNITED STATES. 



like conjectures emanating from ignorance and hasty observers whose 

 names are not infrequently withheld. 



It may, however, facilitate the learned Arbitrators in inquiries into 

 the facts referred to, to indicate the nature of the evidence bearing 

 upon the different points respectively and the places where it may be 

 found. It is believed that nothing more is requisite. Of matters not 

 in any manner drawn in question, little or no notice will be taken. 



II. — Tns Difference between the Alaskan and the Russian 



Fur-Seals. 



The marked differences between the Alaskan and the Russian seals 

 are such as to be plainly and readily discernible to persons familiar 

 with the two herds and their characteristics.. This once established 

 would naturally prove that there is no commingling of the respective 

 herds. But we are not left to inference upon this point, and may con- 

 fidently claim that the proposition is affirmatively established by testi- 

 mony respectable and creditable in itself, while it is wholly uncontra- 

 dicted by proof. 



This is the statement in the Case of the United States: 



The two great herds of fur-seals which frequent the Bering Sea and 

 North Pacific Ocean and make their homes on the Pribilof Islands and 

 Commander (Komandorski) Islands, respectively, are entirely distinct 

 from each other. The difference between the two herds is so marked 

 that an expert in handling and sorting seal skins can invariably dis- 

 tinguish an Alaskan skin from a Commander skin. In support of this 

 we have abundant and most respectable testimony. Mr. Walter E. 

 Martin, head of the London firm of 0. W. Martin & Co., which has 

 been for many years engaged in dressing and dyeing seal skins, de- 

 scribes the difference as follows: "The Copper Island (one of the Com- 

 mander Islands) skins show that the animal is narrower in the neck 

 and at the tail than the Alaska seal and the fur is shorter, particularly 

 under the flippers, and the hair has a yellower tinge than the hairs of 

 the Alaska seals." 



In this statement he is borne out by Snigeroff, a native chief on the 

 Commander Islands and once resident on the Pribilof Islands. 



C. W. Trice, for twenty years a dresser and examiner of raw seal- 

 skins, describes the difference in the fur as being a little darker in the 

 Commander skin. The latter skin is not so porous as the Alaskan skin, 

 and is more difficult to an hair. The difference between the two classes 

 of skins has been further recognized by those engaged in the seal-skin 

 industry in their different market value, the Alaska skins always being 

 held from 20 to 30 per cent more than the "Coppers" or Commander 

 skins. This difference in value has also been recognized by the Russian 

 Government. 



