And since the year 1880 this exercise of sovereignty has been attended by the development of commercial, industrial, and social enterprises, until the district so described has become as much an integral part of the United States as any other portion of the American domain.

STATEMENT IN CONCLUSION.

The United States asserts that the evidence, herewith submitted to the Tribunal and reviewed in the foregoing statement, establishes the following facts:

() That it was the intention of the high contracting parties to the convention of February 16 28, 1825, to confirm in full sovereignty to Russia by that instrument a continuous strip or lisière of territory along the continental shores of the Northwest Coast of America, extending from Portland Canal to the 141st meridian of longitude west of Greenwich.

(b) That it was the intention of the high contracting parties that the width of such lisière was to be 10 marine leagues, measured from the heads of all gulfs, bays, inlets, and arms of the sea-that is, from tide water-unless within that distance from tide water there was wholly or in part a continuous range of mountains lying parallel to the sinuosities of the coast and extending from Portland Canal to the 141st meridian of longitude west of Greenwich, in which latter case the summit of such range was to form the boundary.

(e) That the meaning of the treaty conforms to the intention of the high contracting parties as above stated.

(d) That the acts of Great Britain and Russia subsequent to the signature of the treaty, and the universal interpretation given to its delimiting articles by governments, geographers, cartographers, and historians of those and other civilized nations, agree with and confirm the intention and meaning as above stated.

(e) That the United States purchased the territory from Russia, relying upon such interpretation of the treaty.

(f) That the purchase was open and notorious to the world for the period of one year before the purchase price stipulated in the treaty was paid by the United States to Russia; and that neither during that period nor within thirty years thereafter did Great Britain give notice to the United States that she claimed any portion of the territory then ceded by Russia.

(4) That the United States entered into possession of and occupied

the lisière as above described, exercised sovereign rights therein, and treated the same at all times as a part of its national domain; and to such occupation and exercise of governmental authority Great Britain entered no protest or objection.

() That the United States, from the time of the cession from Russia, has remained in continuous and undisturbed possession of the territory ceded to it.

() That the beginning of the southern boundary between the British and Russian possessions was Cape Muzon, which at the time of the negotiation of the treaty of 1825, and long after, was believed to be one of the southern points of Prince of Wales Island, and so appeared upon the maps and charts of the period.

(j) That Portland Channel was the body of water now commonly known and described as Portland Canal.

(4) That there is not at any point within 10 marine leagues of tide water, between the head of Portland Canal and the 141st degree of longitude west of Greenwich, the whole or any part of a continuous range of mountains parallel with the sinuosities of the coast and extending from Portland Canal to the said 141st degree of longitude; and therefore the width of the lisière, above described, is not limited by a boundary line along the summit of such range, but solely by the agreed distance of 10 marine leagues from tide water.

(7) That the boundary line, determined by the treaty of 1825, began at Cape Muzon and ran thence in an easterly direction to the entrance to Portland Canal between Wales and Compton islands; thence northeasterly along the center of Portland Canal to a point equidistant from Pearse Island and Ramsden Point; thence northerly along the center of Portland Canal until the line touched the mainland at the head of Portland Canal; thence upon the same course continued to the 56th parallel of north latitude; thence northwesterly, always 10 marine leagues from tide water, around the head of Lynn Canal; thence westerly, still following the sinuosities of the coast at a distance there from of 10 marine leagues, until the line intersected the 141st meridian of longitude west of Greenwich; and thence due north along that meridian to the shore of the Arctic Ocean.

The United States, upon the facts established by the evidence herewith submitted, claims that the questions referred for decision to the

Tribunal, as set forth in Article IV of the treaty, should be answered and decided as hereinafter stated; and it therefore recites such questions and makes specific request as to each, as follows:

1. What is intended as the point of commencement of the line?

The United States requests the Tribunal to answer and decide that Cape Muzon is the point of commencement above mentioned.

2. What channel is the Portland Channel?

The United States requests the Tribunal to answer and decide that Portland Channel is the same body of water now commonly known and described as Portland Canal, which, passing from the north between Ramsden Point on the mainland and Pearse Island, and thence southward of said island and Wales Island, enters Dixon Entrance between the island last mentioned and Compton Island.

3. What course should the line take from the point of commencement to the entrance to Portland Channel?

The United States requests the Tribunal to answer and decide that the line from Cape Muzon should be drawn in an easterly direction until it intersects the center of Portland Channel at its opening into Dixon Entrance.

4. To what point of the 56th parallel is the line to be drawn from the head of the Portland Channel, and what course should it follow between these points?

The United States requests the Tribunal to answer and decide that the line should be drawn from the head of Portland Channel northeasterly along the same course on which said line touches the mainland at the head of Portland Channel until it intersects the 56th parallel of north latitude.

5. In extending the line of demarcation northarard from said point on the parallel of the 56th degree of North latitude, following the crest of the mountains situated parallel to the coast until its intersection with the 141st degree of longitude west of Greenwich, subject to the condition that if such line should anywhere exceed the distanc· of ten marine leagues from the ocean, then the boundary between the British and the Russian territory should be formed by a line parallel to the sinuosities of the coast and distant therefrom not more than ten marine leagues, was it the intention and meaning of said convention of 1825 that there should remain in the exclusive possession of Russia a continuous fringe

or strip of coast on the mainland, not exceeding ten marine leagues in width, separating the British Possessions from the bays, ports, inlets, harens, 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 wrest of the meridian of Greenrich?

The United States requests the Tribunal to answer and decide that it was the intention and meaning of said convention of 1825 that there should remain in the exclusive possession of Russia a continuous fringe or strip of coast on the mainland not exceeding ten marine leagues in width, separating the British possessions 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?

The United States, insisting that the fifth question should be answered in the affirmative, as above requested, therefore submits that an answer to the sixth question is unnecessary. But if the Tribunal should decide otherwise and answer the fifth question in the negative, then the United States, without waiving the request made as to the answer and decision of the fifth question, requests the Tribunal to answer and decide that in the event of the summit of such mountains proving to be more than ten marine leagues from the coast, the width of the lisière, which was to belong to Russia, should not be measured from the mainland coast of the ocean, strictly so-called, along a line perpendicular thereto; but that it was 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 from the heads of such 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 requests the Tribunal to answer and decide that such mountains do not exist within ten marine leagues from the coast.