2G2 ARGUMENT OF THE UNITED STATES. 



which could only be furnished by a person who had practically studied 

 the subject. He says: 



In May the bulls commence to haul up on the rookeries, and the 

 cows come three or four weeks later. The bulls choose such ground as 

 they mean to hold through the summer, fight savagely, and the 

 strongest wins. Each has his own family, and should a stranger 

 approach, there is war. On the rookeries one may see all classes of 

 seals, apart from each other, the bulls and breeding cows in one place 

 and the young in another. The pups are born on the rookeries, and 

 remain with their mothers, living wholly upon their mother's milk 

 until they can go into the sea and care tor themselves. There is noth- 

 ing on the beach for the old ones to eat, and they go several miles 

 from the rookeries out to sea to obtain food. When the pups are born 

 they can not swim, and the mothers take them to tl\e water's edge, 

 where one can see thousands paddling and struggling in the surf. The 

 noise made by the mothers crying for their pups, and the bleating of 

 the pups in answer, make a constant roar. The cow is three years old 

 before she bears young. The pups are about forty-five days old before 

 they can go into the water, but they nurse the mother as long as they 

 stay on the island. 



This testimony, if reliable, and there is no reason to dispute its ac- 

 curacy, establishes the dependence of the pup upon its mother not only 

 for food, but for care and instruction in swimming. 



Joseph Stanley-Brown, whose contributions to the subject of fur-seal 

 life and their habits are extremely valuable and are frequently referred 

 to in the Case of the United States, is very emphatic and satisfactory 

 upon this subject. His qualifications have already been stated in con- 

 nection with other propositions. He says (ibid., pp. 15-16) : 



For the first few days, and possibly for a week, or even ten days, the 

 female is able to nourish her young or offspring, but she is soon com- 

 pelled to seek the sea for food, that her voracious young feeder may be 

 properly nourished, and this seems to be permitted on the part of the 

 male, even though under protestation. The whole physical economy 

 of the seal seems to be arranged for alternate feasting and fasting, and 

 it is probable that in the early days of its life, the young seal might be 

 amply nourished * * * without herself resorting to the sea for food. 



The female gives birth to but a single, pup. The labor is of short 

 duration, and seems not to produce great pain. In the first weeks of 

 its life, the pup does not seem to recognize its mother, but the latter 

 will recognize and select her offspring among hundreds. 



The young, upon being born, have all the appearance of pups of a 

 Newfoundland dog with flippers. On emerging from their warm rest- 

 ing place into the chill air, they utter a plaintive bleat not unlike that 

 of a young lamb. The mother fondles them with many demonstra- 

 tions of affection, and they begin nursing soon after their birth. * * * 



The young seals require the nourishing care of their mother for at 

 least four months, and pups have been killed on the island late in 

 November the stomachs of which were filled with milk. * * * 



The pups are afraid of the water; they have to learn to swim by re- 

 peated efforts, and even when able to maintain themselves in the quiet 



