58 Trans. Acad. Sci. of St. Louis 
fight over a certain female, give a chosen one and search in to 
elsewhere for a mate.’’ But it is evident now that the fighting 
is not for a female but for the defense of a boundary, that fight- 
ing may be most vigorous before a female arrives or after she 
is incubating and that, in the case of the Lark, very little or 
no fighting occurs during courtship, nest-building or egg-laying 
for then the male stays within the bounds of an established ter- 
ritory and most sedulously attends his mate. 
The Nesting 
Season of nesting.—One would expect the dates of nests and 
the dates of song to correspond, and so they do, roughly. Song 
begins in late January, nests, as a rule, in March; song ceases 
in early July but nesting may not cease until August ap- 
proaches. 
The beginning of songs in January, in the depth of winter, 
in a setting of barren, wind-swept, unprotected plains and hills 
is not more incongruous than an incubating Lark sitting on her 
eggs in the sleet and snow of March squalls. 
Four records of February nests have been found in the lit- 
erature: The first of these is that of Linden (Forest and 
Stream XIV, 489) who found ‘‘Eremophila cornuta’’ with half 
fledged young the middle of February at Buffalo, New York. 
This article has not been available to the writer and is given 
here on the authority of the statement in the Bulletin of the 
Nuttall Ornithological Club, 5, 1881, 50. The second is that of 
Nelson (no date but circa 1880), who, writing of birds of north- 
eastern Illinois says ‘‘Sometimes the last of February.’’ The 
third is of a nest with eggs in February at Plymouth, Michigan, 
found by Mr. J. B. Purdy and reported by Cook (1893). The 
fourth February nest is mentioned in Bendire (1895), who 
writes of a nest ‘‘found in the vicinity of Milwaukee, Wisconsin, 
Feburary 23.’’ It is quite possible that February nests are not 
uncommon for the birds frequently in February, in my OWD 
observations, presented all the activities of nesting. Sutton 
(1917), Jones (1910), Barnes (1890) are a few among the many 
writers who mention the ‘‘late winter’’ or February mating a¢- 
tivities of this Lark. Yet nests, prior to the beginning of in- 
cubation, are next to impossible to find, as will be shown later, 
