248 ARGUMENT OF THE UNITED STATES. 



own distinctive feeding grounds and peculiar grounds of migration. 

 No doubt they are of the same species, but there is a marked differ- 

 ence in the fur of the skins from the respective places, which can be 

 distinguished by experts. 



C. A. Williams (ibid., p. 535) : Mr. Williams is a citizen of the United 

 States, a resident of the city of New London, in the State of Connec- 

 ticut, and was at the time of testifying 03 years of age. He had been 

 largely engaged for a period of upwards of forty years in the whaling 

 and sealing business, in which he had employed upward of twenty-five 

 vessels. He says that there is no intermingling of the herds. 



The testimony of Alexander McLean (ibid., p. 430) is to the same effect. 

 Mr. McLean is a master mariner and had been engaged for ten years, 

 at the time of making his deposition, in the business of hunting seals 

 in the Pacific or Bering Sea. 



To the like effect is the testimony of Daniel McLean (ibid., p. 443). 

 He, too, is a master mariner, and is of opinion that the Kussian and 

 Alaskan herds are ditt'erent herds of seals altogether. His testimony 

 is as follows : 



Q. In your opinion, do the seals on the Russian side intermingle 

 with those on the Pacific side? A. No, sir ; I do not think so. They 

 are different seals in my opinion. 



It is only just to add that the British Commissioners virtually make 

 the admission that these herds are separate and distinct, although the 

 inference may be drawn, from some of their statements, leading to a 

 contrary conclusion, when the practical question arises in connection 

 with an appreciable difference in the value of skins. 



Thus, for instance, the suggestion is made of a probability in the 

 future, in a course of years, that a continued "harassing" of one group 

 might result in a corresponding gradual accession to the other, by 

 which it is no doubt intended to convey the idea that unless the kill- 

 ing on the Pribilof islands is discontinued the seals will migrate and 

 adopt a Russian domicile (Sec. 453). 



But the same paragraph admits that "the fur-seals of the two sides 

 of the North Pacific belong in the main to practically distinct migra- 

 tion tracts." They add that it is not believed that any voluntary or 

 systematic movement of fur-seals takes place from one group of breed- 

 ing islands to the other (Sec. 453). See also section 198 of British Com- 

 missioners' report, that "while there is every reason to believe that the 

 seals become more or less commingled in Behring Sea during the sum- 



