COUNTER-CASE OF GREAT BRITAIN. 123 



The statement that the fur-seals might remain in the vicinity of the Pribyloft' Islands 

 throughout the year if the winter were less rigorous, is unimportant; for their 

 stay is admitted, under the actual circumstances, to be impossible. 



The expression "home" or ''sole home," as applied in the C'nso of the United States 

 to the Pribylotf Islands, in connection with the fur-seals found in the eastern part 

 of the Pacific, eveu on the assumption that all are born there, is inadmissible. A 

 migratory animal cannot be said to be "at home," only when in its breeding area. 

 The home of any species is the area over which it habitually lives. Animals 

 may have winter as well as summer homes, as stated by Dr. Merriam and other 

 naturalists. 



The principal "winter home" of the fur-seals of the eastern part of the North Pacific, 

 is that part of the sea lying ofi' the coast of British Columbia; and there enor- 

 mous quantities of food fishes, which would otherwise be available for the sup- 

 port of the inhabitants, are consumed by the seals; which even enter the inner 

 waters along the coast and prey upon the food fishes there. 



IT IS ADMITTED THAT THE LARGER NUMBER OF THE FUR-SEALS 

 OF THE EASTERN PART OF THE NORTH PACIFIC RESORT TO 

 THE PRIBYLOFF ISLANDS TO BREED. 



Some of the assertions above formulated have already 

 been in part dealt with, being to a certain extent involved 

 ill other contentions brought forward in the United States 

 Case in regard to seal life. 



It has been shown that the term "Alaskan seal herd," as Elliott, census 

 employed in the Case of the United States, is intended to ^^^Mouograph 

 denote all the fur-seals found in the eastern part of the of North Imen- 

 North Pacitic. Most of these seals are doubtless born jk mt. '"°'^''' ^' 

 upon the Pribylofif Islands, and the young remain on ^iiid ^^^^"'i-^ ^"s- 

 about these islands till such time as their size and strength ii,Tarti°p.'io5. ' 

 enables them to permanently assume their natural pelagic of N^rtii'Ameri'- 

 liabits. After leaving the islands, they appear to remain* an Pinnipeds," 

 entirely at sea till at least the middle of July in the next^^^ite^i states 

 year. In regard to the fur-seals of the Southern Hemi- Case Appendix, 

 sphere the young animals never again come on shore dur- ^° i-pP'^^e.s?*. 

 iiig the first year of their lives, and there is much reason 

 to believe that similar circumstances obtain in the North 

 Pacific. Thus, Bryant says of the young females: 



At this stage they [the female pups] leave the island for the winter, f"2^*'?,''^'"^P^ 

 and very few a^ipear to return to the island until they are three years °jjjj p^nuipedT" 

 old. pp. 401, 402. 



In the United States Case many authorities are cited 

 with the object of proving that the birth of the fur-seal 

 at sea is impossible. The British Commissioners report 



practically in accordance with this view, or to the 

 143 effect that such birth, if possible, is so infrequent as 



to be of no practical imiiortance; though the fact that 

 the sea-otter brings forth its young on masses of floating 

 kelp shows it to be not impossible that the fur-seal may at 

 times also do so. 



FORMERLY BRED AT OTHER PLACES ALONG NORTH- 

 WEST COAST, AND PROBABLY STILL DO SO. 



In regard to the birth of fur-seals at other places alon 

 the American coast besides the Pribyloft" Islands, the Brit- 

 ish Commissioners, however, write as follows: 



It is evident that many years ago a considerable number of fur- British Com- 

 seals bred in various places ahiug the western coast of North America, missioiiers' R e- 

 .... The traditions of the Indians of the coast of British Colum- J"""'^' '"*''*• **^- 



