260 ARGUMENT OF THE UNITED STATES. 



agent for the Alaska Commercial Company, at Chernofsky, and for 

 ten years he had acted in the same capacity at Umnak. Ho had every 

 opportunity, as will appear from his deposition on page 210, Vol. II, 

 of the Appendix to the Case of the United States, to observe the habits 

 of the seals. 



This is his language: 



I have seen seals sleeping on kelp and feeding about it, but have 

 never seen them copulate anywhere except on a rookery. I do not be- 

 lieve that pups born on kelp could be properly nursed and brought up. 

 I do believe that it is necessary to their successful existence that they 

 be born on land, since they can not swim at birth. 



Norman Hodgson (ibid., p. 3G7), a resident of Port Townsend, iu 

 the State of Washington, and a fur-seal hunter by occupation, gives 

 many interesting details as to the habits of the seal. On the point 

 now under consideration, he says: 



I do not believe it possible for fur- seals to breed or copulate in the 

 water at sea. and never saw or heard of the action taking place on a 

 patch of floating kelp. 1 have never seen a young fur seal pup of the 

 same season's birth in the water at sea on a patch of floating kelp, and, 

 in fact, never knew of their being born anywhere save on a rookery. I 

 have, however, cut open a gravid cow and taken the young one from 

 its mother's womb alive and crying. 1 do not believe it possible for a 

 young fur-seal pup to be successfully raised unless born and nursed on a 

 rookery. 1 have seen fur-seals resting on patches of floating kelp at 

 sea, but do not believe they ever haul up for breeding purposes any- 

 where except mi the rookeries. 



Charles Bryant, who had spent considerable time on the Islands and 

 had acted during a period of nine years as special agent of the Treas- 

 ury Department, says (ibid., p. 0): 



In watching the seals while swimming about the islands, I have seen 

 cases wheie they appeared to be copulating in the water, but lam cer- 

 tain, even if this were the case, that the propagation of the species is 

 hot as a rule effected in this way, the natural and usual manner of 

 coition being upon land. 



Capt. James W. Budington, who testified to his experience, which 



was considerable, iu seal hunting at Cape Horn and in the Southern 



Atlantic Ocean, say (ibid., p. 595): 



1 am also convinced that copulation takes place on land before they 

 migrate, the period of gestation being about eleven months. 



Samuel Falconer, a witness whose experience and qualifications 



have been mentioned heretofore, says (ibid., p. 1(35): 



