ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 351 



experience tliat must necessarily liave been acquired by these gentle- 

 men, that tliey have sohl four-fifths of all the skins sold in London since 

 the year 1870. It is almost a monopoly of that business for the last 

 twenty years; and if there is any source of information to which we 

 can resort with a hope of being satisfied, it must certainly be here. 



The next proposition of fact is one which is admitted, I think, and 

 therefore I shall not offer any proof upon the subject, viz, that the herd 

 returns to the islands. 



Then the bulls and cows go to the breeding grounds, the non-breed- 

 ing males to the hauling grounds. 



Upon this, as those expressions are constantly used in the Case, per- 

 haps a brief explanation would be well to show the court what the 

 difference is between the breeding and the hauling grounds. Those of 

 the honorable Arbitrators w^ho have not examined the question, will be 

 curious perha])s to see, and interested to learn how the instinct of these 

 animals guides them to make their respective homes on their general 

 abode. 1 am reading from the Case of the United States, at page 91, 

 where it is said : 



The "breeding grounds" or "breeding rookeries" (the areas occnpied by the 

 breeding seals and their offspring — that is the bulls, the cows and the pups) . . . are 

 rocky areas along the water's edge, covered with broken pieces of lava of various 

 sizes and shapes, those nearest the sea having been rounded by the action of the 

 waves and the ice; between the rocks are sometimes found smooth spaces of ground, 

 but in no case are these areas of any extent, and they vary greatly in size. 



So strong is the instinct, so imperative the necessity of obedience to 

 that instinct that, as I have already read, these animals not only go 

 back to the island and to the same general locality, but the bulls in 

 many instances have been found — the same bulls — to take precisely 

 the same spot. 



That is for the breeding grounds. The hauling grounds are thus 

 spoken of in our Case : 



The "hauliug grounds" (areas occupied by the non breeding seals) are the sandy 

 beaches at one side of the breeding grounds, or the smoother spaces back of and 

 contiguous to the breeding seals. Tiie areas covered by the rookeries on the respec- 

 tive islands vary considerably, being in the ratio of about seven or eight on St. Paul 

 to one on St. George. 



It has appeared all through the Case that St. George was smaller 

 than St. Paul, and that there was a very nuich smaller number of 

 seals on it. St. Paul is lower than St. George, the shores are broader, 

 and more territory is available upon it for occupation by seals than on 

 the latter, which accounts in a measure for the disproportion in seal 

 population on the two islands. 



I will not dwell upon this any further. We also state, and that prop- 

 osition is not dis])uted, that the fur-seal is a jwlygamous animal. I 

 would read in connection with this but three or four lines from the 

 report of the British Commissioners, in section 37, on page 7. 



Among the first of the more stringent measures adopted was the restriction of 

 killing to males. 



That is, measures or regulations adopted on the islands. Let me, 

 however, i^reface this by saying that when the United States bought 

 from Russia, this industry, established by Russia and carried on by 

 her, was intelligently carried on with a due discrimination as to sex. 

 We introduced no innovation, except that we souglit to improve the 

 methods already in operation, jinrtly by elevating the character of tlie 

 residents in the place, and partly by such additional regulations for 

 the protection of seal life as might be suggested. 



