6354 APPENDIX TO CASE CF GREAT BRITAIN. 
tude, nor in the seas which washed those coasts, he intended to make a distinction 
between Behring’s Sea and the Pacific Ocean. But on reference to a Map it will be 
seen that the 60th degree of north latitude strikes straight across Behring’s Sea, 
leaving by far the larger and more important part of it to the south; so that I con- 
fess it appears to me that by no conceivable construction of his words can Mr. Mid- 
dleton be supposed to have excepted that sea from those which he declared to be free. 
If his Lordship had examined his Map somewhat more closely, he would have found 
my statement literally correct. When Mr. Middleton referred to ‘ the Conti- 
44 nent of America between the 50th and 60th degrees of north latitude,” it was 
impossible that he could have referred to the coast of Behring’s Sea, for the 
very simple reason that the 50th degree of latitude is altogether south of the Behring’s 
Sea. The fact that the 60th parallel “strikes straight across the Behring’s Sea” has 
no more pertinence to this discussion thanif his Lordship had remarked that the same 
parallel passes through the Sea of Okhotsk, which lies to the west of Behring’s Sea, 
just as the arm of the North Pacific lies to the east of it. Mr. Middleton was deny- 
ing Russia’s dominion upon a continuous line of coast upon the continent between 
two specified points and over the waters washing that coast. There is such a con- 
tinuous line of coast between the 50th and 60th degrees on the Pacific Ocean; but 
there is no such line of coast on the Behring’s Sea, even if you measure from the 
southernmost island of the Aleutian chain. In a word, the argument of Lord Salis- 
bury on this point is based upon a geographical impossibility. (See illustrative 
Map on opposite page. ) 
But, if there could be any doubt left as to what coast and to what waters Mr. Mid- 
dleton referred, an analysis of the last paragraph of the 4th Portocol will dispel that 
doubt. When Mr. Middleton declared that ‘‘the United States have exercised navigation 
in the seas, and conmerce upon the coasts above mentioned, from the time of their inde- 
pendence,” he makes the same declaration that had been previously made by Mr. Adams. 
That declaration could only refer to the north-west coast as I have described it, or as 
Mr. Middleton phrases it, ‘‘the Continent of America between the 50th and 60th 
degrees of north latitude.” 
Even his Lordship will not dispute the fact that it was upon this coast and in the 
waters washing it that the United States and Great Britain had exercised free navi- 
gation and commerce continuously since 1784. By no possibility conld that navigation 
and commerce have been in Behring’s Sea. Mr. Middleton, a close student of history, 
and experienced in diplomacy, could not have declared that the United States had 
‘exercised navigation” in the Behring’s Sea, and ‘‘commerce upon its coasts,” from 
the time of their independence. As a matter of history, there was no trade and no nay- 
igation (except the navigation of explorers) by the United States and Great Britain 
in the Behring’s Sea in 1784, or even at the time these Treaties were negotiated. 
Captain Cook’s voyage of exploration and discovery through the waters of that sea 
was completed at the close of the year 1778, and his ‘“‘ Voyage to the Pacific Ocean” 
was not published in London until five years after his death, which occurred at the 
Sandwich Islands on the 14th February, 1779. The Pribyloff Islands were first dis- 
covered, one in 1786 and the other in 1787. Seals were taken there for a few years 
afterwards by the Lebedef Company of Russia, subsequently consolidated into the 
Russian-American Company; but the taking of seals on those islands was then dis- 
continued by the Russians until 1803, when it was resumed by the Russian-American 
Company. , 
At the time these Treaties were negotiated there was only one Settlement, and that 
of Russians, on the shores of the Behring’s Sea, and the only trading vessels which 
had entered that sea were the vessels of the Russian Fur Company. Exploring 
expeditions had, of course, entered. It is evident, therefore, without further state- 
ment, that neither the vessels of the United States nor of Great Britain nor of any 
other Power than Russia had traded on the shores of Behring’s Sea prior to the nego- 
tiations of these Treaties. No more convincing proof could be adduced that these 
Treaties had reference solely to the waters and coasts of the continent south of the 
Alaskan Peninsula—simply the “Pacific Ocean” and the ‘north-west coast” named 
in the Treaties. 
ae IlIrd Article of the British Treaty, as printed in the British State Papers, is 
as follows: 
“The line of demarcation between the possessions of the High Contracting Parties 
upon the coast of the continent and the islands of America to the north-west shall 
be drawn in the manner following: 
“Commencing from the southernmost point of the island called Prince of Wales 
Island, which point lies in the parallel of 54° 40’ north latitude, and between the 
131st and the 133rd degree of west longitude (meridian of Greenwich), the said line 
shall ascend to the north along the channel called Portland Channel, as far as the 
point of the continent where it strikes the 56th degree of north latitude; from this 
