64 COUNTER-CASE OF GREAT BRITAIN. 



MR. WILLIAMS DOES NOT THINK THAT MORE THAN A 

 DOZEN PEOPLE KNEW THAT THE PURCHASE CONTAINED 

 ANYTHING OF VALUE OUTSIDE THE MAINLAND. 



Mr. C. A. Williams, in liis evidence, given before a Com- 

 mittee of Congress, said : 



50th Cong., 2ml I do not think, when the Government made the purchase from Rus- 



Sess., H. K. Ke- sia, that any one outside of a dozen people, perhaps, who had been 



port, No. 3883, p. jj^j>,jygj,,^g(l with sealing' heretofore, had the slightest knowledge of 



there being any value in those islands, or that the Government was 



going to get anything of value outside the mainland of Alaska. 



Dr. W. H. Ball, who is specially quoted as an authority 

 on Alaska in the United States Case, wrote a letter to cor- 

 rect certain statements attributed to him in the discussion 

 arising from a paper by Mr. W. Palmer, read before the 

 Biological Society at Washington. In this letter Dr. Dall 

 says: 



73 DR. DALL MENTIONS SMALL VALUE OF SEAL-fcKINS IN 1866, AS 



REASON WHY LITTLE STRESS WOULD HAVE BEEN LAID ON THE 

 ACQUISITION OF THE SEALS BY THE UNITED STATES. 



"Forest and j g;ii[\ that iu 1866 (not " in the early days of the industry") I pur- 

 ^*ream "Noveni- (.jj^yg^^ tirst-class fur-seal skins at 12^ cents a-piece, that being the 

 "' ^ price at which they wer(^ sold by the Russians. The point of this 



observation lies in its application to the oft-repeated statement that, 

 as Mr. Palmer savs, "little stress was laid upon the fact that fur-seals 

 were found in abunaauce" at the time of the purchase of the Territory 

 by the United States. No stress could reasonably have been laid upon 

 it, since 100,000 seals would at that time have been worth only some 

 12,500 dollars, which would hardly have paid for the trouble of taking 

 them. Of course, almost immediately afterwards this was no longer 

 true. 



It is submitted that the contentions of the United States 

 are based upon two assumptions, both of which are entirely 

 erroneous. 



The lirst, that, prior to the year 1867, Eussia had, in fact, 

 excluded the vessels of other nations from Behring Sea. 



The second, that the language of the Treaty of 1867 

 describes, and purports to convey, some special rights in 

 the uon- territorial waters of Behring Sea. 



CONCLUSIONS. 



As to the first, the considerations contained in the pre- 

 ceding Chapters have established that, prior to 1867, Kussia 

 had not, at any time, excluded from Behring Sea the ves- 

 sels of foreign nations. 



As to the second, a reference to the language of the 

 Treaty— which is set out at pp. 91 to 91 of the British Case — 

 shows that Russia was conveying territories which were 

 then admitted to form part of the Russian Empire, but with 

 no more than the ordinary territorial rights. 



