Reproduction 57 
male’s full song ‘‘with a bright snatch of her own.’’ The male, 
though, stays with her assiduously during the nest-building and 
egg-laying and may be observed frequently strutting with wings 
dropped, tail spread and horns up. Furthermore he has a little 
note of greeting that he reserves for her. It sounds like ‘‘eheck’’ 
or ‘‘cheek’’. On only one occasion did I see a female become 
pugnacious toward another Lark. In this instance she was 
guarding a youngster just from the nest. A neighboring male, 
in curiosity over this activity, invaded her territory to investi- 
gate, forthwith she got up and had at him with a fury well 
worthy of an Amazon. But, inconsistently, a moment later 
she fled before him as he made a second sally. 
In connection with this study of territories and courtship I 
should like, in conclusion, to make a few comparisons between 
these observations and those of others. They show, most clearly, 
the whole change in attitude toward the activities of birds in 
courtship and nesting since the publication of Howard’s (1920) 
famous studies of ‘‘Territories in Bird Life.’’ Thus Jones 
(1892), in one of the most anthropomorphic descriptions en- 
countered, says of the Larks that if a second suitor appears on 
the scene and the female shows ‘‘no preference” then the issue 
rests upon a battle which is short and decisive. She accepts 
the suitor of the previous year unless he has been killed (Jones 
does not say how he knew this) otherwise two young fellows 
vie with each other. The female usually shows a preference 
otherwise a battle follows. In any case battle is the ‘‘court of 
final appeal.’’ If a female loses a mate she at once ‘‘seeks 
another and always finds him.’’ And many more similar and 
untenable comments. Though, on the whole, the account of 
Harris (in Bendire, 1895) is the most extensive and thorough 
of any in the literature, some of his observations too are not 
now, with our present knowledge of the significance of territories, 
tenable. He says, for instance, after giving an admirable ac- 
count of the manner in which Larks fight, when “suitors for the 
same female’’: ‘‘The victorious suitor then quickly returns to 
his coveted mate and struts before her with raised ear tufts and 
trailing wings, very much in the same manner as the English 
Sparrow.’’ Lastly, and scarcely justifiable in the light of mod- 
ern research, Sutton (1927) writes, ‘‘I believe the birds are 
essentially pacific and that males, rather than have a prolonged 
