40 COUNTER-CASE OF GREAT BRITAIN. 



In section 1 of the tbiid Charter, the Enssian-Anierican 

 Company is referred to as being — 



United States established for trading on the continent of North-Western America 

 Case, p. 28. ,^ij,\ q,j ^^q Aleutian and Kurile Islands, as in every part of the North- 



E astern Sea, *tc. 



"NORTH-EASTERN SEA'' (OR OCEAN) MEANS PACIFIC 

 OCEAN, AS IS PI 

 ISLANDS THEREIN 



OCEAN, AS IS PROVED BY INCLUSION OF KURILE 



The above quotations are destructive of the conchtsion 

 endeavoured to be established. It is evident from both 

 l)assages that the term "North-Eastern Ocean " or "North- 

 Easterii Sea" was employed not as a special designation of 

 Behriug !Sea, but as a synonym of Pacific Ocean. The 

 Kurile Islands are in the Pacific Ocean, bufwholly outside 

 Behring Sea. 



"EASTERN OCEAN" MEANS PACIFIC OCEAN. 



With regard to the alternative term "Eastern Ocean," 

 United states two authorities are quoted in the Case of the United States 

 Case, p. 53. with the object of showing that by this name Behring Sea 

 Ibid., Appeii- was indicated, viz., "Coxe's Eussiau Discoveries," and a 

 dixi,p.29o. globe by D. Adams, London, dated 1797. For details re- 

 A])pendix,v(,i. specting tliesc, the Appendix to this Counter-Case must 

 i,pp. loj, 104. ^Q referred to. It may here be stated, however, that, in 

 Coxe's work, " Eastern Ocean" is again found to be a syno- 

 nym for the Pacific Ocean, and that tlie names upon the 

 globes published hy Adams do not appear to throw any 

 light upon the jnatter. 

 Ibid., pp. 103, From the notes given in the Appendix, the meaning of 

 ^^*" the term "Eastern Ocean" (which, though com])aratively 



seldom used, is to be found on some Maps) is clearly shown 

 to be synonymous with the'Pacific Ocean. Attention 

 British Case, 45 jg particularly drawu to the several Kussian Maps 



Appendix, vol. ^ •^ ■■■ 



ii i. "United thcie enumerated. 



fi89i),"pp^88,'89^ Any argument founded on the use of a particular name 

 by geographers may be conclusively answered by the fol- 

 lowing quotation from Lord Salisbury's despatch, dated 

 the 2ist February, 1891 : 



BAYS AND GULFS AUK NONE TUK LESS PART OF THE MAIN SEA FOR 

 HAVIN(; A SPECIFIC NAME, f. g., BAY OF BISCAY AND GULF OF 

 LYONS. 



But I am not prepared to admit the jnstice of Mr. Blaine's coEtcntion 

 that the words "Pacific Ocean" did not include Behring Sea. I be- 

 lieve that in common parlance, then and now, Behring Sea was and 

 is part of the Pacific Ocean ; and that the latter words were used in 

 order to give the fullest and widest scoi)e possible to the claim which 

 the British negotiators were solenmly recording of a right freely to 

 navigate- and fish in every part of it, and throughout its entire extent. 

 In proof of the argument that the words "Pacific Ocean" do not 

 include Behring Sea, Mr. Blaine adduces a long li-3t of Maps in which 

 a designation distinct liom that of " Pacific Ocean" is given to Beh- 

 ring Sea ; either " Behring Sea," or " Sea of Kamschatka," or the "Sea 

 of Anadir." The argument will hardly have any force unless it ia 

 applicable with equal truth to all the other oceans of the world. 

 But no one will dispute that the Bay of Biscay forms part of the 



