236 ARGUMENT OF THE UNITED STATES. 



undressed state from that of the Alaskan and Northwest Coast skins. 

 They are of an entirely distinct and separate herd, while those of the 

 Northwest Coast and Pribilof Islands are of the same variety. He 

 says: 



I have been in the business for twenty-eight years during which time 

 I have bought large numbers of dressed and undressed fur skins, and 

 I am thoroughly familiar with the business. 1 can easily distinguish 

 the Copper Island fur-seal skin in its undressed state from that of the 

 Alaskan and Northwest Coast skins. They are of an entirely distinct 

 and separate herd, while those of the Northwest Coast and Pribilof Is- 

 lands are of the same variety. 



To the same effect Mr. GustaveNiebaum (ibid., p. 78), Mr. Niebaum's 

 experience was such as to entitle him to speak as an expert. His 

 opportunities to inform himself thoroughly on all matters connected 

 with sealeries were of the best, and at the same time he had no interest 

 whatever in the sealeries or the seal-skin trade. He is a native of Fin- 

 land and became an American citizen by the transfer of Alaska to the 

 United States. He was vice-consul of Kussia at San Francisco from 

 1880 to 1891. He says: 



I was formerly, as I have stated, interested in the Commander 

 seal islands, as well as those of Alaska. The two herds are separate 

 and distinct, the fur being of different quality and appearance. The 

 two classes of skins have always been held at different values in the 

 London market, the Alaskan bringing invariably a higher price than 

 the Siberian of the same weight and size of skins. I think each herd 

 keeps upon its own feeding grounds along the respective coasts they 

 inhabit. 



Tt may be unnecessary — as it would certainly bo monotonous — to 

 multiply citations. Other witnesses, however, testify to the same effect. 

 The American Commissioners have given their names and addresses, 

 as well as their sworn statements. The Arbitrators will, therefore, be 

 enabled to determine whether or not the evidence is, as we claim that 

 it is, absolutely conclusive. In a court of law, such a concensus of 

 opinion and statement made under the sanction of an oath and uncon- 

 tradicted, save by more or less ingenious but unsustained conjecture, 

 would satisfy the judgment of the most exacting judge. Other depo- 

 sitions equally important may be quoted in addition to the above. 



Mr. Walter E. Martin (ibid., p. 5G9), was, at the time of giving his 

 testimony, a subject of Her Majesty, residing at the city of St. Albans. 

 He had been engaged, on a very large scale, in the business of dress- 



