AKGUMENT OF SAMUEL J. ELDER. 1501 



northwardly, because that was the crux of the case, the possession of 

 the upper part of Lynn Canal. 



Turning to map 16, at Baranof Island, and following along down 

 to Cape Ommaney, there is a line drawn 21f miles to Coronation 

 Island, and from there to Cape Addington a line drawn 31f miles; 

 and then, following along the coast from Cape St. Bartolomew down 

 to Dall Island, 27^ miles; and then across from Cape Muzon to the 

 mainland of Prince of Wales Island, 14 miles. The Tribunal will 

 remember that Mr. Ewart, in good-natured raillery, said that that 

 was easy, after the jumps that we had previously been taking. And 

 then across from Cape Chacon, 27$ miles to the Cape of Northum- 

 berland ; and then a line 13$ miles over to the mainland, very near 

 54 40', which is the end of the boundary line in that direction. And 

 the contention was that the United States was pointing out that line, 

 as it has been followed, and as Mr. Ewart followed it, as the political 

 coast line, not confining itself to 3-mile bays, but jumping indefinite 

 distances, 31 miles and other considerable distances. 



The United States Government never suggested any such line as 

 that. It never proposed any such line as that, and there is nothing 

 in the record which, understood properly, can give any justification 

 or foundation for the claim. It is a flight of imagination greater 

 than the flights across from one cape to the other, and to the end of 

 proving it, let me call attention to the original question and the 

 original position of the United States. 



The United States came into the rights of Eussia, and there was 

 a treaty between Russia and Great Britain with reference to this 

 matter which is found on the 15th page of the Alaska Boundary 

 reprint by the United States, the 15th page of the Appendix to the 

 Case of the United States in that arbitration. The line of demarca- 

 tion was to be the crest of the mountain ranges which follow the shore 

 of Behring Sea. But whenever there was no range of mountains 

 within 10 marine leagues of the shore, then the line was to follow the 

 coast. Let me read the passage. It is under the fourth subdivision 

 on that page, the section marked 2 : 



" 2. That whenever the summit of the mountains which extend in 

 a direction parallel to the coast, from the 56th degree of north lati- 

 tude to the point of intersection of the 141st degree of west longitude, 

 shall prove to be at the distance of more than ten marine leagues 

 from the ocean, the limit between the British Possessions and the 

 line of coast which is to belong to Russia, as above mentioned, shall 

 be formed by a line parallel to the windings of the coast, and which 

 shall never exceed the distance of ten marine leagues therefrom." 



I believe that the French word translated " windings " might as 

 well be translated " sinuosities ; " windings or sinuosities. 



The contention of the United States in this Alaska Boundary Arbi- 

 tration was that, there being no mountain range within 10 marine 



