382 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



Mr, CouDEKT. — It is No. in our book of maps, "Seizures, 1891", 

 aud it will show that those ships then had no scruples as to being in 

 our waters because every one of them, as indicated on this map, are in 

 American waters. Without dwelling upon that map, I sim^dy call atten- 

 tion to it. 



Sir Charles Eussell. — You mean east of the line? 



Mr. CoUDERT. — Yes. We have it, then, that in 1891, notwithstanding 

 the obstacles interposed, there were 28,888 seals killed by the pelagic 

 sealers. We take issue with our learned friend on the other side when 

 he assigns a Russian domicile to those seal in the main. On the con- 

 trary, we claim tliat they were caught, if not all, at least the greater 

 part of them, on our side of the Behring Sea. 



But I proi)Ose to go on with tlie <[uestion that was under discussion, 

 and to read now more about this sealing from page 180 of our Case. 

 That is as to the method: 



The vessel commonly used in sealing is a scboouer ranging from twenty to one 

 hundred and lifty tons burden; the average tonnage per vessel for the Victoria fleet 

 in 1892 being 63.2 tons. 



That is the average tonnage per Vessel, 03 and a fraction. I continue: 



The number of hunters and canoes or boats carried by a sealer depends upon the 

 size of the vessel, but the average number of canoes is between ten and sixteen, each 

 manned by two Indians, aud wlien tlie hunters are whites the boats generally num- 

 ber live or six. In some eases both Indians and whites are employed on the same 

 vessel. Tiio average number of men to a vessel in 1890 was twenty-two. 



The Indian hunter almost invariably uses a spear, aud though in the last two or 

 three years firearms have been carried in the canoe, the principal weapon used by 

 him is still the spear. A full description of the spear, canoe, and manner of hunting 

 is given by Lieut. .T. H. Quiunau, who ac:jompanied some of the Indians in their 

 canoe during a hunting excursion. The most expert spearsmen are the Makah 

 Indians of Neali liay, Washington. The Indian, from his method of hunting loses 

 very few seals that he strikes, securing nearly all. 



The white hunter, on the contrary, loses a great many seals which he kills or 

 wounds. Each boat contains a boat-steerer, and a boat-puller; the hunter uses a 

 rifle, a shotgun, or 1)oth, the shotgun beiugloaded with buckshot. A minute descrip- 

 tion of the methods emjiloyed by both white and Indian hunters is given by C'apt. 

 C. L. Hopper, commander of the United States revenue steamer Corwin, who was 

 many years in the waters of the North Pacific and Behring Sea, and makes his state- 

 ments from personal observation. 



I will give the Tribunal some tlgures. I read now from page 366 of 

 the Case of the United States, from the reports of the Behring Sea and 

 the report of the American Commissioners. We have the catch for all 

 the years from 1872 to 1891, on i)age 360. The sources of information 

 upon which the table is l>ased that we submit to the Tribunal are given 

 in the note, and they will be found to come from sources whicli are not 

 open to suspicion, but if they could in any way be supposed to favour 

 either party, it would be our friends on the other side: 



The number of seal ski 'is actually recorded as sold as a result of pelagic sealing is 

 shown in the following table: 



1872. 

 1873. 

 1874. 

 1875. 

 1876. 

 1877. 

 1878. 

 1879. 

 1880. 

 1881. 



Yc;'.r. 



No. of 

 .skins. 



1,029 



4, 949 

 1,046 

 2, 042 



5, 700 

 9, 593 



V>, 500-1- 

 13,000 

 13, 541 



Tear. 



1882 

 18S3 

 1884 

 18S5 

 1886 

 1887 

 1888 

 1889 

 1S;1(1 

 1891 



No. of 

 skins. 



17, 700 

 9, 195 

 ' 14, 000 

 13, 000 

 38, 907 

 33, 800 

 37, 789 

 40, 9S8 

 48,319 

 62, 508 



* if limber estimated from value given. 



