sessions from the bays, ports, inlets, havens, and waters of the ocean, and extending from the said point on the 56th degree of latitude north to a point where such line of demarcation should intersect the 141st degree of longitude west of the meridian of Greenwich?

6. If the foregoing question should be answered in the negative, and in the event of the summit of such mountains proving to be in places more than ten marine leagues from the coast, should the width of the lisière which was to belong to Russia be measured (1) from the mainland coast of the ocean, strictly so-called, along a line perpendicular thereto, or (2) was it the intention and meaning of the said convention that where the mainland coast is indented by deep inlets, forming part of the territorial waters of Russia, the width of the lisière was to be measured (a) from the line of the general direction of the mainland coast, or (b) from the line separating the waters of the ocean from the territorial waters of Russia, or (c) from the heads of the aforesaid inlets?

7. What, if any exist, are the mountains referred to as situated parallel to the coast, which mountains, when within ten marine leagues from the coast, are declared to form the eastern boundary?

The United States herewith submits to the Tribunal the printed Case, provided for by Article II of the convention, together with the documents, the official correspondence, and other evidence upon which it relies. But it specifically reserves the right to present hereafter to the Tribunal such other evidence as it may properly do under the provisions of Article II, either obtained from Great Britain upon demand or in pursuance of any notice given of its intended introduction by reference thereto in the printed Case.

The printed Case will consider and treat the subject of the controversy as follows: (1) The historical facts concerning the Northwest Coast of America prior to 1821, which led up to the controversy of Russia with the United States and Great Britain; (2) the diplomatic negotiations between the three nations, which culminated in the treaties of 1824 and of 1825; (3) the results of the negotiations; (4) the negotiations between the United States and Russia following the expiration of the reciprocal trade privilege granted by the treaty of 1824; (5) the occupation of the territory by Russia up to the year 1867; (6) the cession of Alaska to the United States in 1867, and the universally accepted interpretation of the treaty provisions delimiting the boundary prior to and at the time of the cession; and (7) the complete, continuous, and undisturbed occupation of the territory by the United States since the cession from Russia.

The printed Case is accompanied by an Appendix containing the historical, geographical, and topographical evidence in support of the

statements made in the printed Case, and also by an Atlas of maps and charts in evidence and as explanatory of facts set forth on behalf of the United States.

THE NORTHWEST COAST OF AMERICA.

The Northwest Coast of America, extending from the Strait of Juan de Fuca northward to the sixtieth parallel of north latitude, was the last seaboard of the continent to be occupied by Americans and Europeans. Its remoteness from the Atlantic ports and the difficulty of access to it by land made this region but little known to the world before the close of the eighteenth century.

While England, France, and Spain had been planting colonies on the eastern side of the continent and were gradually extending their settlements westward, Russia had pushed her way eastward across Siberia and reached the shores of the Pacific. Under the energetic rule of Peter the Great the exploration of the North Pacific was planned, but was not actually undertaken until after his death. In 1728 Vitus Bering," in command of an expedition fitted out by the Imperial Government, discovered the strait between America and Asia, and reached the continent of North America in latitude 65 north. Thirteen years later this navigator made a second voyage in which he again sighted the continental shore. He explored the Aleutian chain and discovered the Commander Islands, upon one of which he was shipwrecked and died.'

Numerous Russian traders and adventurers, induced by the opportunities offered of obtaining furs for the Chinese market at Kiakta," made voyages into the regions visited by Bering, and by 1778, when Capt. James Cook entered Bering Sea, the Russians were firmly estab

In the spelling of proper names the Report of the United States Board of Geographic Names (Washington, 1901) and the Geographic Dictionary of Alaska, by Marcus Baker, (issued as Bulletin No. 187 of the United States Geological Survey, 1902) are followed.

Burney's History of Northeastern Voyages of Discovery and of the Early Eastern Navigations of the Russians, London, 1819, pp. 130, 176, 183; Greenhow's Memoir on the Northwest Coast of America, in Senate Doc. 174, Twenty-sixth Congress, first session, p. 82.

Coxe's Russian Discoveries between Asia and America (4th ed.), London, 1804, p. 466.

lished throughout the Aleutian Islands." In 1781 Gregory Shelikof, of Rylsk, and other Siberian merchants, who had been engaged in the fur trade in eastern Asia, formed an association, and two years later three vessels were fitted out by them, which, under the command of Shelikof, traversed the Pacific to the peninsula of Alaska. The following year this navigator erected a factory on Kadiak Island.' With this station as a base he sent out expeditions to explore the neighboring continent and establish trading posts at convenient points."

Having continued his explorations for five years, and on his return to Siberia having received a medal and portrait from Catherine II in recognition of his services, Shelikof organized, in 1790, at Irkutsk, the Shelikof Company, which under imperial patronage secured a partial monopoly of the American fur trade. Delareff, who had been with the head of the company during his cruises, was made chief director, and Alexander Baranof was chosen to conduct the factories at Kadiak and Cooks Inlet. Two years later the latter became the manager of the company.

Meanwhile, independent traders had extended their operations to the continent, and the competition was working disaster to the Irkutsk Company, which had also suffered by the death of Shelikof. The most powerful of these rivals were persuaded to unite their interests with the older association in 1798, under the name of "The Shelikof United Trading Company," but new competitors sprang up and continued to demoralize the trade. The unfavorable conditions induced the United Company to attempt to secure an imperial grant of exclusive trade privileges in America and the Aleutian Islands." As a result of its efforts, there was promulgated on July 8, 1799, an imperial ukase, which organized the "Russian American Company,"

Voyage to the Pacific Ocean under the direction of Captain Cook and Others, London, 1784, Vol. III, pp. 359–383.

Coxe, p. 207 et seq.

Coxe, pp. 269–292: Appendix, p. 251. (All references to "Appendix" are to the Appendix accompanying this Case unless otherwise stated.)

Alaska and Its Resources, William H. Dall, Boston, 1870, pp. 309, 311.

Dall., pp. 312, 314.

Historical Review of the Development of the Russian American Company, and of Its Operations up to the Present Time, P. Tikhmenief, St. Petersburg, 1861, Vol. I, p. 61; Appendix, p. 253.

9 Dall., p. 317.

Dall, p. 318.

and granted to it, for the term of twenty years, a monopoly of the trade and the exclusive occupation of that part of the American coast north of the 55th degree of north latitude, besides the Russian islands on both sides of the Pacific Ocean and Bering Sea, the right to make discoveries, and to occupy new lands as Russian possessions on either side of the 55th parallel, not previously occupied by any other nation, and the authority to administer, fortify, and defend its colonies."

The ukase of 1799 created a colonial system similar in its essential features to that established in North America under the charter of the Hudson's Bay Company and in India by the East India Company. The Russian American Company became the representative of the monarch within the regions named in the ukase, possessing the sovereignty by delegation and exercising all the functions of governmental authority.

The office of the company, originally at Irkutsk, was soon transferred to St. Petersburg, where members of the imperial family became shareholders in the enterprise, insuring continuance of the favor and aid of the crown. At the head of the colonial government was placed Baranof, the energetic director of the Shelikof Company, who "maintained for twenty years an absolute despotic sway over the colonies."

In the same year in which the ukase was granted, Baranof proceeded to Norfolk Sound (now known as Sitka Sound), where he erected a fortified post, which was subsequently captured by the natives, who massacred the garrison. In 1804 another fort was constructed under Baranof's direction, a short distance from the site of the one destroyed, which was named Fort Archangel Michael, the factory being called New Archangel. From this new establishment the Russian American Company's traders were able to extend their operations through the archipelago lying southward of the 60th parallel of latitude, and along the continental shores opposite.

While the ukase of 1799 accomplished its purpose in preventing the interference of other Russian traders with the monopoly granted to the chartered company, it was ineffectual in keeping the trading

a Appendix, p. 23.

b Dall, p. 320.

Dall, p. 319.

₫ Dall, p. 322; Appendix, p. 62.

vessels of the United States from frequenting the islands and inland waters along the Northwest Coast and from trading with the natives. The American traders conveyed their cargoes of furs to Canton, where they disposed of them at large profits." The returns were such as to induce other merchants of the United States to engage in the industry, and from 1790 the number of vessels constantly increased."

These independent traders unquestionably impaired the value of the Russian American Company's monopoly as they secured a considerable proportion of the skins sold by the natives. They were further favored in this competition by the advantage of being permitted by the Chinese authorities to dispose of their furs at Canton, which possessed direct communication with the sea, and which was closed to the Russians. Attempts by the latter to open trade with that port had been made, but were futile. As a result, the Russian American Company was forced to transport their furs by ship to the Siberian coast and thence hundreds of miles overland to the border town of Kiakta. Under such conditions the American traders secured a decided advantage over their competitors.

Baranof, however, instead of incurring the enmity of his rivals, endeavored to turn their facilities for trade with China to account by employing them to carry the company's furs to Canton and sell them on commission. While the company thus found it profitable to preserve amicable relations with the Americans, the latter were, nevertheless, a source of annoyance to the chief director through using firearms and ammunition as articles of barter with the natives. The increase in this traffic finally caused Russia, through its representative at Washington, to call the attention of the United States Government to the course pursued by its traders. In 1808 the Russian chargé d'affaires was directed by the Minister of Foreign Affairs to express "the hope that this illicit traffic" would meet with the disapprobation of the American Government, and that rigid orders would put a stop to it.

@A Statistical View, etc., of the United States, Thomas Pitkin, New York, 1817, p. 249; A Narrative of Voyages, A. Delano, Boston, 1817, p. 306.

Appendix, p. 61.

eVoyage Round the World in the Years 1803-1806, A. J. von Krusenstern, London, 1813, Vol. II, p. 341; Appendix, p. 64.

& Appendix, p. 63.