APPENDIX TO CASE OF GREAT BRITAIN. 813 
the 20th day of July, 1890, when the sealing season had not expired, and when 
47 said Company had obtained only one-third of the quota of seal-skins which 
by law and the terms of said Contract it was authorized to take, and then and 
there prohibited said Company from taking any additional number during said year, 
on account of which said Company sustained a ioss in the sum of 400,000 dollars. 
“Said Company further represents that at the time it was compelled to stop 
taking seals at said islands it earnestly protested against such action by the United 
States, and has continued to protest, and now again submits its formal protest 
against the action of the United States in preventing it from taking its quota of 
seal-skins it had aright to take by law and by the terms of said Contract. And said 
Company respectfully submits that it is justly entitled to receive from the United 
States such a sum as will compensate it for the loss it has sustained on account of 
the action of the United States, as aforesaid. 
“2. Said Company further represents that, acting under the authority of law and 
the provisions of said lease, the Secretary of the Treasury, on the 15th day of April, 
1891, determined and fixed the quota of seal-skins which said Company would be 
permitted to take on said islands, according to the provisions of said Contract, dur- 
ing the present year, at 60,000 skins; and that, relying upon that assurance, said 
Company again purchased a large stock of supplies to the amount of 65,000 dollars, 
and chartered a steamer at great expense to transport said supplies to the seal islands 
for the maintenance of the native inhabitants, and to bring to San Francisco the 
60,000 seal-skins which it had been authorized to take during the present season. 
“And now, said Company having been notified by the Secretary of the Treasury 
that it will not be permitted to take its said quota of 60,000 seals during this year 
as it is authorized to do by its said Contract, and by the express direction of the 
Secretary aforesaid, and it respectfully enters its protest against such action by the 
United States, and gives notice to the Honourable the Secretary of the Treasury 
that it will claim to be reimbursed by the United States to the full amount of the 
loss it may sustain by reason of its being prohibited by the United States from taking 
its full quota of 60,000 seal-skins during the year 1891. 
“3. Said Company further represents that in providing for the maintenance and 
education of the inhabitants of the Islands of St. Paul and St. George aforesaid, it 
has expended a large amount of money, to wit, the sum of 150,000 dollars, for which 
it has not been reimbursed in any part, and said Company has been assured by the 
Secretary of the Treasury that the United States will liquidate the account so 
expended by said Company, including as well the price of supplies and cost of 
schools, medicines, and medical attendance during the years 1890 and 1891. Said 
Company will be obliged to hereafter demand of the United States the full amount 
so expended. 
“Said Company respectfully invites the attention of the Secretary of the Treasury 
to the fact that the Islands of St. Paul and St. George in Alaska belong to and are in 
the undisputed possession of the United States; that the right of this Government 
to dispose of fur-seals born on said islands has never been questioned. ‘This being 
so, said Company assumes that the right of the United States or its lessee to take 
fur-seals on said islands within our unquestioned jurisdiction is beyond dispute, and 
not subject to question or interference by England or any other foreign State. 
“The right of this Government to take fur-seals on its own territory is not one of 
the questions to be submitted to arbitration, and has no relation to the contention 
between the two countries. In that dispute Great Britain affirms and the United 
States denies the right of English and Canadian poachers to slaughter fur-seals in 
‘our part’ of Behring’s Sea, and this Company respectfully insists that the Agree- 
ment between the two Governments set forth in the President’s Proclamation, in so 
far as it prohibits said Company from taking its lawful quota of seal-skins, is in con- 
travention of the vested rights of this Company, and subjects it to great loss. 
“Tf it may be assumed, as England has asserted, and this Government has denied, 
that the eastern portion of Behring’s Sea is not the marine territory of the United 
States, but is the ‘high seas,’ the Company respectfully submits that it is not compe- 
tent for Great Britain and the United States alone or for any other two Governments 
to determine who shall be permitte:l to navigate these waters, or to prohibit fishing 
or taking seals on the high seas; and the Company respectfully points out to the 
Honourable the Secretary of the Treasury that its rights have been overlooked by 
said Agreement between the two Governments, in that it deprives the lessee from 
taking seals which it is authorized to take by law and its Contract with the United 
States, thereby inflicting a severe loss upon said Company, in order to obtain the 
consent of England to arbitrate the question as to the right of Canadian poachers to 
destroy the seal industry by pelagic sealing.” 
