254 ARGUMENT OF THE UNITED STATES. 



Captain Morgan says (ibid., p. 01): 



I believe that the cause the seals choose these islands for their home 

 is because of the isolation of these Pribilof Islands and because the 

 climatic condition of these Pribilof Islands is peculiarly favorably to 

 seal life. During the time the seals are upon land the weather is damp 

 and cool, the islands being almost continually enveloped in fogs, the 

 average temperature being about 41° F. during the summer. 



See, too, Daniel Webster, local agent for the North American Com- 

 mercial Company, and stationed on St. George Island, who uses the 

 following language (ibid., p. 180): 



These islands are isolated and seem to possess the necessary climatic 

 conditions to make them the favorite breeding grounds of the Alaskan 

 fur-seals, and it is here they congregate during the summer months of 

 each year to bring forth and rear their young. 



Mr. Redpath, a resident of St. Paul Island, Alaska. He had resided 

 on the seal islands of St. Paul and St. George since 1875, that is to 

 say, at the time of giving his deposition, some seventeen years. He 

 testified as follows upon this point (ibid., p. 148): 



The Alaskan far seal is a native of the Pribilof Islands, and, unless 

 prevented, will return to those islands every year with the regularity 

 of the seasons, .ail the peculiarities of nature that surround the Pribi- 

 lof group of islands, such as low and even temperature, fog, mist, and 

 perpetual clouded sky, seem to indicate their fitness and adaptability 

 as a home fur the Alaskan fur-seal; and with an instinct bordering on 

 reason, they have selected these lonely and barren islands as the choicest 

 spots of earth upon which to assemble and dwell together during their 

 six months stay on land; and annually they journey across thousands 

 of miles of ocean, and pass 1 undreds of islands, without pause or rest, 

 until they come to the place of their birth. And it is a well-established 

 fact that upon no other land in the world do the Alaskan fur-seal haul 

 out of water. 



IV. — The Entire Office of Eeproduction and Bearing- of 

 Young is and must be Performed on Land. 



"The act of coition takes place upon land" (Case of the United 

 States, p. 110). The correctness of this assertion is settled beyond 

 controversy by the overwhelming proof furnished by the United States 

 Commissioners. But had they produced no evidence whatever, it is 

 clear that the data furnished by the British Commissioners themselves 

 are insufficient to cast reasonable doubt upon the proposition. 



(a) The British Commissioners, in their report, begin with the broad 

 (and incorrect) statement that the fur-seal is an animal in its nature 



