96 COUNTER-CASE OF GREAT BRITAIN. 



sumecl by the seals individually and also as a whole, is 

 dealt with later iu this Counter-Case (p. 152); and it is 

 there shown to amount to many millions of tons annually. 

 It is still further worth3^ of remark that but a small pro- 

 portion of this food is derived even from the neighbourhood 

 of the Pribyloff Islands, for it is admitted in the United 

 Seals do not States Case that the bulls do not feed during the period 

 iu^'^t'Jth^bmfd-^'' which they reside upon the islands; and as to the other 

 ing-isiauds. seals fiequeutiiig the islands, the British Commissioners 

 were of opinion that they also do not feed whilst on or 

 British Com- about the islauds. In support of this belief they quote the 

 port^"para8 ^42' f^^t that the rookeries and hauliug-grouud were searched 

 243.' ' — -• jjj y^j,j £qj^. any traces of excrement, and that, having killed 

 a considerable number of seals of all descriptions, and 

 examined the contents of their stomachs, no trace of food 

 i ^^144°*^^^' '*^'' w^s found. Continued observations iu 1892 entirely sup- 

 port this opinion. 



CONCLUSIONS. 



It is, therefore, evident that no grouuas exist to justify 

 the application to the fur-seal of the designation of land 

 animal, when admittedly it derives its entire sustenance 

 from the ocean, and passes there two-thirds, if not more, of 

 its existence. 



Ill Section II. — The Ftir-seal is in no sense a Domestic Animal. 



The United States Contentions. 



(1.) United States Case, p. 295 — 

 "The seal is domestic iu its habits and readily controlled by man while on the 

 land." 

 (2.) United States Case, p. 154 — 

 "The killing of a portion of the surplus male life is undoubtedly a benefit to the 



herd, as it is with other domestic and polygamous animals." 

 (See also pp. 147 to 150, "Control and Domestication.") 



Summary of British Reply. 



Though fur-seals are to a certain degree controllable when on land, this results from 

 their helplessness while there, and such control has nothing to do with domesti- 

 cation. 



The seals are now fearful of man, even when collected in great numbers ashore ; 

 tbongh it is probable that, when their breeding-places were first visited, igno- 

 rance caused thoni to be fearless. 



All ideas attached to the word "domestic" are wanting in the ease of fur-seals. 

 Man does not provide their food; his care is at most of a negative kind, and con- 

 sists in the avoidance of acts which tend to drive them wholly away from the 

 t>reeding-island8. They would not suffer, but, on the contrary, would profit by 

 his departure from these islands. 



During the greater part of the year the seals are wholly removed from the cogni- 

 zance of persons on the Pribyloff Islands; and till very lately their winter 

 haunts were not even known. 



No scientific evidence can be adduced in support of the contention that the seal is 

 other than a wild animal ; and it is believed that no credible evidence from any 

 source cau be quoted to such au effect. 



