ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 333 



Pribilof Islands, that there is no means of ascertaining from the kind 

 of skin, its colour, its fineness, its texture, and the like, whether they 

 are our seals or not, an argument might be made, and it might be said 

 "If you will tell us how to recognize your seals, we will respect them". 



May I trespass upon the indulgence of this High Court and dwell 

 upon this point which, as you see, in its ramifications is of the highest 

 imjiortance: it affects the skins of the animals, where they come from, 

 how they are to be identified. When the skin is removed from the 

 animals, it is sent to London, which is the great centre where the indus- 

 try is carried on of preparing the skin, and where they are all received. 



So also the Commander skins, is there any diflerence'? If there is 

 any difference, if there is a different species of animals, — if they are as 

 different as Jersey and Guernsey cows, — if there is such a difference as 

 between the breed of horses known as the Percheron and Norman, if 

 there is a difference in the skins, we propose to prove, and I think the 

 evidence is overwhelming that there is such a difference in the skin 

 itself as to shew, apart from any other consideration or argument, that 

 these are entirely distinct families. 



We are now leaving the sphere of testimony in which the pelagic 

 sealers and the inhabitants of the Pribilof Islands figure so largely, 

 and we can call up Mr. Bevingtou. His testimony is cited, I will say 

 for the convenience of our friends on the other side, in the Argument of 

 the United States, page 233. Of course, these gentlemen are men who 

 stand very high in commerce. Their position is one which entitles 

 them to be treated with great respect especially when they are testify- 

 ing in favor of the United States. We are bound to give them the 

 highest credit. 



This is on page 233. Mr. Bevington is called. He is a subject of Her 

 Britannic Majesty; 40 years of age; the head of the firm of Bevington 

 and Morris, 28 Cannon Street in the city of London. His testimony as 

 a whole will be found in volume 2 of the Appendix; but I will not read 

 the whole. He says upon the subject of the variations observable: 



That the cliiferences between the three several sorts of skins last mentioned, 



that is of the Commander Islands, the Pribiloff Islands, and the Eob- 

 ben Islands, 



are so marked as to enable any person skilled in the business or accustomed to han- 

 dle the same to readily distinguish the skins of one catch from those of another, 

 especially in bulk, and it is the fact that when tliey reach the market the skins of 

 each class come separately and are not found mingled with those belonging to the 

 other classes. The skins of the Copper Island catch are distinguished from the skina 

 of the Alaska and Northwest, 



Perhaps this high Tribunal will not understand what the Northwest 

 catch may be. It is the Pribilof Island seals killed by hunters. That 

 is what the northwest catch is. They are all Alaska seals; they are 

 all the same family of seals, some killed with discrimination upon the 

 land, and the others killed without discrimination ujion the sea: 



Which two last-mentioned classes of skins appear to be nearly allied to each other 

 and are of the same general character, by reason of the fact that in their raw 

 state, 



He is speaking of the Copper skins. 



the Copper skins are lighter in colour than either of the other two, and in the 

 dyed state there is a marked difference in the appearance of the fur of the Copper 

 and the other two classes of skins. This difference is difficult to describe to a person 

 unaccustomed to handle skins, but it is nevertheless clear and distinct to an expert, 

 and may be generally described by saying that the Copper skins are of a close, short 

 and shiny fur, particularly down by the flank, to a greater extent than the Alaska 

 and Northwest skins. 



