66 ORAL ARGUMENT OF JAMES C. CARTER, ESQ. 



I must attempt to summarize that answer of Mr. Blaine, without 

 reading the letter, which is very long, and which I assume, of course, 

 the learned Arbitrators will themselves carefully read. I must 

 endeavor to present a summary of it, and it is this: Mr. Blaine's 

 argument is that long prior to the year 1821, Russia had, by prior dis- 

 covery and prior occupation, gained an absolute title to all tbe territory 

 surrounding Bering Sea; that upon the Siberian coast she had no rival 

 whatever, and had comi)]ete possession of the whole territory from Ber- 

 ing Straits down to the 47th parallel of latitude, or in that vicinity: that 

 she had pushed her discoveries on the American coast of Bering Sea 

 also, and had a recognized title to all the territory from Bering Straits 

 down to the 54th degree of latitude, at least, and that she had dis- 

 covered, and asserted her title to, the whole chain of the Aleutian 

 Islands: that all that was long x>rior to the year 1821, indeed prior to 

 1800: that in the year 1821 she issued her celebrated ulcase, the prin- 

 cipal point of which was that she asserted an exclusive right to all the 

 products of this whole region, to all the trade of the whole region, and 

 for the purpose of protecting that product and that trade, a right to 

 exclude the vessels of all nations from a belt 100 miles from the shore 

 along all the islands and coasts of the sea. That was her assumption 

 by the ukase. The governments of Great Britain and the United 

 States objected to those claims; but the principal ground of their 

 objection was not to any assumption of authority over the sea, nor to 

 any assumption of authority over the sliores of Bering Sea, as to 

 wliich the wliole world admitted that the title of Russia was exclusive, 

 but to the extension of her assertions of exclusive dominion on the 

 coast from about the ])arallel of 54 North latitude down to the parallel 

 of 51. The i^oint of Mr. Blaine was that the objectionable feature of 

 the ukase in the eyes of both Great Britain and the United States was 

 the assumption of exclusive territorial sovereignty over this coast, from. 

 the southern part of Alaska down over a long range of coast which 

 had been familiarly called in commerce and by merclmnts and navi- 

 gators who were engaged in trade there the "Northwest Coast". It 

 was the theatre of tlie rival enterprises of several different nations in 

 commerce. Merchants in the United States had a large trade up there. 

 Great Britain had a large trade there, and Russia had a very consider- 

 able trade up there. 



The President. And Spain also. 



Mr. Carter. And Spain also had some, although I do not know 

 how much it amounted to commercially. She had made pretensions, 

 of course, as we all know, which were subsequently transferred to the 

 United States. 



The President. On account of the possession of San Francisco, on 

 that coast. 



Mr. Carter. Ah, lower down, of course, Spain had great preten- 

 sions; but San Francisco, I think, was rather below what was com- 

 monly termed the Northwest Coast. Spain claimed to parallel 00, I 

 know; but I am speaking of the extent of commerce which she actually 

 had up there. I do not think it was very considerable. Her claims 

 extended up there, that we know. I am speaking of the fact that this 

 Northwest Coast, so called, was the theatre of a veiy extensive trade, 

 l>rincipally carried on by three great powers, Great Britain, the United 

 States and Russia. Mr. Blaine's argument was that the principal point 

 of contention between these Governments was the sovereignty assumed 

 by Russia over that coast, which, if successfully maintained by her, would 

 exclude both Great Britain and the United States from the benelit of 

 that trade. 



