COUNTER-CASE OP GREAT BRITAIN. 41 



Atlantic Ocean, oi' tliat the Gnlf of Ijyons forms part of the Mediter- 

 raiienn Sea; and yet in most Maps it will he ibuiid that to those por- 

 tions of the larger sea a separate designatiou has heen given. The 

 question whctherby the words " Pacific Ocean" the negotiators meant 

 to include or exclude Behring Sea depends upon which locution was 

 esteemed to he the correct usage at the time. The date is not a dis- 

 tant one, and there is no ground for suggesting that the usage has 

 "^hanged since the Angln-.Ru.ssia Treaty of 1825 was signed. The de- 

 termination of this point will he most satisfactorily ascertained by 

 consulting the ordinary books of reference. I append to this despatch 

 n list of some thirty works of this class, of various dates from 1795 

 downwards, and printed in various countries, which combine to show 

 that, in customary parlance, the words " Paciuc Ocean" do include 

 Behring Sea. 



The list referred to in tbe above quotation lias been Appeuaix, voi. 

 greatly increased, and is printed in an Appendix to this*- pi*- **''''* "'^• 

 Connter-Case. The special attention of the Arbitrators is 

 invited to tlie language of the various authors cited, which 

 leaves no doubt whatever but that, at the date of the 

 Treaty, Behring Sea was, as it still is, regarded by geogra- 

 jjhers as i>art of the Pacific Ocean. 



COMMANDER ISLANDS ARE DESCRIBED IN THE TREATY 

 OF 1867, AS IN PACIFIC OCEAN. 



The language of the Treaty of Cession of Russia to the British ca.se. 

 United States in the year 1867 is entirely in accordance par'tTn?p^ 4.'"' 



with the contention of Her Majesty's Cxovernment; 

 46 for in that document, it will be found that the Com- 

 mander Islands are properly described as being in 

 the Pacific Ocean. 



GEOGRAPHICAL SKETCH OF BEHRING SEA IN UNITED 

 STATES CASE, MISLEADING. 



An attempt is apparently made in the Case of the United 

 States to support the theory that IJehring Sea is a body of 

 water distinct in its nature from the Pacific Ocean, by the 

 terms in which the geographical sketch of this sea are set 

 out in the opening pages. The geographical sketch there 

 given, though brief, is, it is submitted, essentially mislead- 

 ing in its character. 



On ]i. 13 of the United States Case, the Peninsula of United states 

 Alaska is described, apparently for the single purpose of '^'^^^'P*^^' 

 stating that in it there are — 



low-lying marshy gaps which form portages used by the natives for 

 carrying their boats across from the I'acijic Ocean to Bristol Bay. 



As authority for this statement, Eeclus' " Geographie," 

 vol. XV, p. 201, is cited; but, on turning to this work, we 

 find that the passage thus paraphrased actually reads as 

 follows : 



. . , . Lesmontagnes peninsiilaires de I'Alaska .... sent 

 conpees de distance en distance par des seiiils trt s has, des ])ortage8 — 

 en Russe "pereuossi" — que les bateliers praticjuent en elfet pour le 

 transport de leurs barques d'un rtrsant a Vautre versant. 



Reclus, in fact, makes no mention in this connection of 

 the Pacific Ocean or of Bristol Bay; nor does he convey 

 the impression that Bristol Bay is no part of that ocean. 



