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96
ARGUMENT OF THE UNITED STATES.

possess on the Aurerican continent frou the fifty-*ixth degree of north kititade tu the point of intersection of the one handred ani forty-tirst degree of west longitude,

The Entperor woul! have fonod it tere mutually just, more eynally advantageons, if the natural fronticr formed by the mountains bordering on the coast were adopted by both parties as the invariable Hne of demarcation, England would have gained thereby wherever these mountains were les than ten marine leaynes from the sea; Rossin wherever that distance was ureater, andl, in view of the want of accuracy of the geographical notions which we possess us to these countries, such an arrangement would have offered an entire equality of favonible chances to the two contracting yairties.

Can it be imayined that when he was contending for an unviarying mountain boundary for the “limits of the stvip of coast whieh Russia ix to possess,” he understood that he lad receded so far as to take stretches of water as such boundary, had given up a continuous strip for broken strips, and had abandoned the sovereignty of Russia over hundreds of miles of eoust, over which she had always asserted her claim; and that all of this occurred without any discussion or explana- tion, and without even the private correspondence of either govern- ment giving the remotest hintof it¢ The iea ison its face incredible. To hold that such was the effect of the use of the word "eoust” is to convict the plenipotentiaries of Great Britain of the most artful and veiled duplicity imaginable, or those of Russia of a lack of intelli- gence that is incomprehensible.

It would not be possible for any one to vive a clearer and more forcible exposition of what Russia, Great Britain and the United States understood by the “northwest coast and ‘*the coast,”—as to which the jurisdiction of these respective powers was settled by the treaties of 1824 and 1825,—than that given by the distinguished counsel for Great Britain in the Pur Seal Arbitration.

Sir Charles Russell disenssed the question at great lenyth, He said that the phrase northwest coast of America ‘‘extended to the whole of the coast line of the possessions claimed by Russia from Behring Sumit down to its most southern boundary." He quoted from the Ukase as follows:

The pursuits of commerce, whaling and fishery, and of all other industry on all

islands, ports and galis, inelnding the whole of the northwest coast of America, beginning from Bebrings Strait to the Sist degree of northern latitude: also from

«UL S.C. App., 225-228.

Fur Seal Arbitration, Vol. 15, p. 128.