244 ARGUMENT OF THE UNITED STATES. 



islands, and during my long experience in the North Pacific and Ber- 

 ing Sea I never found another locality which possessed those condi- 

 tions so favorable to seal life. Add to this fact the isolated condition 

 of the seal islands and we can readily see why the seal selected this 

 home. 



Mr. Alfred Fraser (ibid., pp. 554, 558) is another witness to whose 

 testimony exceptional importance should be attached. He was of 

 opinion that the herds from which skins are obtained do not in fact 

 intermingle with each other, because the skins classified under the 

 head of Copper catch are not found among the consignment of skins 

 received from the Alaska catch, and vice versa. His testimony is 

 quoted at some length, and is as follows: 



That he is a subject of Her Britannic Majesty and is 52 years of 

 age and resides in the city of Brooklyn, in the State of New York. 

 That he is a member of the firm of C. M. Lampson & Co., of London, 

 and has been a member of said firm for about thirteen years; prior to 

 that time he was in the employ of said firm and took an active part in 

 the management of the business of said firm in Loudon. That the 

 business of C. M. Lampson & Co. is that of merchants, engaged princi- 

 pally in the business of selling skins on commission. That for about 

 twenty-tour years the firm of CM. Lampson & Co. have sold the great 

 majority of the whole number of sealskins sold in all the markets of 

 the world. That while he was engaged in the management of the 

 business of said firm in London, he had personal knowledge of the 

 character of the various sealskins sold by the said firm, from his per- 

 sonal inspection of the same in their warehouse and from the physical 

 handling of the same by him. That many hundred thousands of the 

 skins sold by C. M. Lampson & Co. have physically passed through 

 his hands; and that since his residence in this country he has, as a mem- 

 ber of said firm, had a general and detailed knowledge of the character 

 and extent of the business of said firm, although since his residence in 

 the city of JSTew York he has not physically handled the skins dis- 

 posed of by his firm. 



* # • * • • * 



Deponent is further of the opinion, from his long observation and 

 handling of the skins of the several catches, that the skins of the Alaska 

 and Copper catches are readily distinguishable from each other, and 

 that the herds from which such skins are obtained do not in fact inter- 

 mingle with each other because the skins classified under the head of 

 Copper catch are not found among the consignments of skins received 

 from the Alaska catch, and vice versa. 



Deponent further says that the distinction between the skins of the 

 several catches is so marked that in his judgment he would, for instance, 

 haA T e had no difficulty, had there been included among 100,000 skins in 

 the Alaska catch 1,000 skins of the Copper catch, in distinguishing the 

 1,000 Copper skins and separating them from the 99,000 Alaska skins, 

 or that any other person with equal or let-s experience in the handling 

 of skins would be equally able to distinguish them. And in the same 

 way deponent thinks, from his own personal experience in handling 

 skins, that he would have no difficulty whatever in separating the skins 



