102 COUNTER-CASE OF GREAT BRITAIN. 



of polygamous habit, in tlie impossibility in their ease of the 

 artificial selection of the stronger and finer males for breed- 

 ing purposes. 



NO SCIENTIFIC EVIDENCE ADDUCED IN SUPPORT OF CON- 

 TENTION THAT THE SEAL IS A DOMESTIC ANIMAL. 



It will be noted that neither the United States Behring 

 Sea Commissioners, nor Professor J. A. Allen, in their 

 Reports, venture to characterize tbe fur-sealas a domestic 

 animal, and in fact that Professor Allen, in conformity with 

 facts and usage, distinctly classes it as a wild animal, 

 writing: 



TTnited States The habits of no wild animal during the breeding season are perhaps 



Case, Appendix, i^etter known than are those of the Northern or Alaskan Fnr-Seal. 

 vol. 1. ]). 610. 



CiiM'''lr\5o*'***^^ '^^^ ^^^^ opinion purporting to be of a scientific kind 

 Ibid.,' Appen adduced as evidence, in which the "domestic" character 



dix.voi.i, p.43i.^^. ^1^^ far-seal is atfirmed, is that of Dr. E. von Midden- 

 dorf, of Russia, who writes that the seal " was created for 

 a domestic animal ; " but it is very clear that the writer did 

 not appreciate the meaning of the word "domestic." He 

 writes : 



It is, in fact, the most useful of all domestic animals, since it requires 

 no care and no expense, and consecjuentlj^ yields the largest net profits. 



CONCLUSION. 



It is submitted that there is no just ground for the con- 

 tention that the seal is domestic in its habits. 



118 Section III. — Inter minglimi of Fur-seah of different xmrts of the 



JS^orth Facijic. 



The United States Contentions. 



(1.) United States Case, p. 89— 

 "The Alaskan fur-seal." 



(2.) United States Case, p. 94— 

 "The Alaskan seal herd." 



"The two great herds of fnr-seals which frequent the Bering Soa and North 

 Pacitic Ocean and make their homes on the Pribilof Islands and Commander 

 (Komandorski) Islands, respectively, are entirely distinct from each other." 



(3.) United States Case, p. 96— 



"These two herds of fur-seals do not intermingle, each keeping to its own side 

 of Bering Sea and the Pacitic Ocean." 



(4.) United States Case, p. 323— 



" In winter the fur-seals migrate into the North Pacific Ocean. The herds from 

 the Commander Islands, Robben Reef, and the Kurile Islands move south along 

 the Japan coast, while the herd belonging to the Pribilof Islands leaves Bering 

 Sea by the eastern passes of the Aleutian chain. The fur seals of the Pribilof 

 Islands do not mix with those of the Commander and Kurile Islands at any time 

 of tiie year." 



(5.) United States Case, p. 296— 



"That its [the fur-seal's] course when absent from these islands is uniform and 

 confined principally to waters adjacent. That it never mingles witli any other 

 herd That at all times when in the water, the identity of each indi- 



