and the other in the air, the latter uses its feet only, with effects that are irritating rather than to be feared. Now why is this, and what causes the difference in this respect as between gull and tern? From my own observation I think I can explain it. So long as two contending gulls fight with any equality, they do so upon the ground, but when one of them can no longer hold his own there, he rises into the air and, sweeping backwards and forwards over the other, who stays where he was, annoys him in this particular way. The bird, therefore, by whom these tactics are resorted to has already got the worst of it, and the last thing he wishes is again to close with a rival who has defeated him. This, however, is exactly what would happen were he to use his hooked beak in the manner proper to it, for it is adapted for seizing and tearing, and to these uses it has hitherto been put. To peck or stab with it would be like making a thrust with a sickle, and though possibly as against a weaker antagonist it might be made effectual in some other than the normal way, yet here there is always the fear of detention, to check any experiment of the sort. Let the hooked tip but pierce the skin to any extent, and the swoop would be checked sufficiently to allow of the flying bird's being seized. The feet, therefore, though without efficient claws and quite unadapted to anything except swimming, are employed by preference, and in the manner in which they are used we see the same principle at work, for instead of making any attempt at grasping or scratching, the flying gull,
