of Lausanne to check up these new calculations; (3) "On the conclusion of its new task, the Council of the Ottoman Public Debt shall notify each of the interested states of the rectified total of the annuities it must pay. Any complaints concerning this sum shall be dealt with, upon the request of the state concerned, by the arbitrator, who shall first make written request of said state and of the Council for all the explanations or observations which may be necessary"; (4) Each of the parties will receive upon request a copy countersigned by the arbitrator of the notification of the total amount by the Council, and a full statement of these definite sums shall be deposited with the Secretariat of the League of Nations to be attached to the original copy of the present arbitration.

Sections III, IV, V, and VI take note of various reservations made by the parties in the course of the arbitration and reserve their rights in certain details.

Section VII treats of the question of the compensation of the arbitrator and the allotment of the expenses of the arbitration, which are to be determined by the Secretariat of the League of Nations. These items are to be allotted on the basis of nine parts, three for Great Britain as the mandatory Power for Irak, Palestine, and Transjordania; two parts for France, as the mandatory Power for Syria and The Lebanon; and one part each for Bulgaria, Greece, Italy, and Turkey.

Section VIII provides for the formal filing of the present decision with the Secretariat, and for its distribution.

Under the rubric "Execution of the Decision" the arbitrator has indicated in detail the correct procedure to be followed as prescribed summarily in the text of the actual decision.

It is greatly to be regretted that comment on an arbitral award of such exceptional significance and merit must of necessity be of so cursory a character. But those who may have the special interest as well as the leisure to study the decision in detail will naturally prefer to do so. They will find it an authoritative and illuminating exposition of the problem of state succession as exemplified in a most interesting manner by the two partitions of the old Ottoman Empire as the result of the Balkan Wars of 1912-13, and of the World War.

PHILIP MARSHALL BROWN.

CURRENT NOTES

ANNUAL MEETING OF THE SOCIETY

The Twentieth Annual Meeting of the American Society of International Law will be held at the customary time, namely, the last Thursday, Friday and Saturday of April, which in 1926 fall upon the 22nd, 23rd and 24th days of that month. The Committee on the Annual Meeting has decided that the general subject of the next program will be the codification of international law. The consideration of the subject will be divided between addresses of a general nature, and papers and round table discussions both on the fundamental premises of codification and on the codification of particular topics. The meeting will end with the usual dinner on Saturday evening. The detailed program, with reservation cards for the dinner, will be mailed to the members of the Society in ample time before the meeting.

AMERICAN-BRITISH ARBITRAL TRIBUNAL

What is expected to be the final session of the American-British Arbitral Tribunal convened in Washington on October 26, 1925. As at present constituted, the Tribunal consists of Senator Alfred Nerincx of Belgium, President; Sir Charles Fitzpatrick of Canada, British member; and Judge Roscoe Pound, American member. On November 10th, the Tribunal dismissed seven claims against the United States based on injuries said to have been inflicted on British subjects in Hawaii by the Hawaiian Republic shortly before its annexation by the United States. The Tribunal held that the United States was not liable in international law to redress wrongful acts committed by Hawaii. The Tribunal also rendered several awards in favor of American fishermen because of the disregard by Newfoundland of their rights under the Treaty of 1818 as construed by the Hague Tribunal in 1910.

On November 20th, the Tribunal dismissed twenty claims of British subjects for the destruction of their property by Filipinos after the signature of the Treaty of Peace between Spain and the United States but before it had come into force. Counsel for the British Government argued that the United States was responsible because of the delay of American officials in responding to the claimants' request for protection and because of the negligent manner in which the American forces operated when they landed. The tribunal sustained the contentions of the American agent that since the Treaty of Peace had not come into force when the damage took place, the United States was under no obligation to protect British interests, that no negligence could properly be attributed to the American officials, and that the British Government could not under international

law call the United States to account because of alleged inefficiency of its military and naval forces.

PREVENTION OF SMUGGLING ALONG THE MEXICAN BORDER

On December 23, 1925, the Secretary of State and the Mexican Ambassador at Washington signed a convention for the prevention of smuggling operations along the Mexican boundary, such as narcotics, intoxicating liquor, merchandise, and the smuggling of aliens. The convention is similar to that concluded with Canada on June 6, 1924, and printed in the Supplement to the JOURNAL for October, 1925 (Vol. 19), page 120. The convention also contains a section providing for an International Fisheries Commission between the United States and Mexico to study the question of the conservation of certain fisheries on the Pacific Coast. At the same time, a supplementary extradition convention was signed by the two countries adding to the list of extraditable crimes offenses against the law for the suppression of traffic in narcotic drugs similar to the convention with Canada which was signed on January 8, 1925.

COMMERCIAL AND CONSULAR TREATY BETWEEN THE UNITED STATES

AND ESTHONIA

The Secretary of State and the Minister of Esthonia in Washington on December 23, 1925, signed a treaty of friendship, commerce and consular rights similar to the one between the United States and Germany signed on December 8, 1923, and printed in the Supplement to this number of the JOURNAL, page 4, the two treaties differing only in a small number of minor particulars necessary to meet special conditions. The treaty provides for unconditional most-favored-nation treatment as applied to nationals of each country in the other, and to commerce between the two countries. The reservations in relation to immigration and shipping made by the Senate in giving its advice and consent to the ratification of the treaty with Germany were accepted by Esthonia and incorporated in the treaty.

COMMERCIAL AGREEMENT BETWEEN THE UNITED STATES AND LITHUANIA

By an exchange of notes at Washington on December 23, 1925, the United States and Lithuania have entered into a commercial agreement providing reciprocally for unconditional most-favored-nation treatment in the levy of import and export duties and in certain other matters affecting commerce. The agreement will become operative after approval by the Lithuanian parliament. The texts of the notes exchanged are practically identical with the notes exchanged between the United States and Lithuania on March 2, 1925, and printed in the Supplement to this JOURNAL for October, 1925 (Vol. 19), p. 136.

AIRCRAFT BETWEEN THE UNITED STATES AND CANADA

By an exchange of notes between the Department of State and the British Embassy in Washington, the agreement between the United States and Canada, with regard to the entry of United States pilots and aircraft into Canadian territory, has been extended to and including April 30, 1926. This arrangement has been in effect since 1922 and provides in general that when an American machine or pilot wishes to cross the international boundary and fly in Canada, notification should be sent in advance to the Secretary of the Air Board, Ottawa, giving the date of the proposed flight, the owner's name and address, the pilot's name and qualifications, the type of machine to be used, the route and duration of the proposed flight, and the purpose for which it is being undertaken. Special provisions cover commercial aircraft, private aircraft, and customs regulations.

In this connection, it is to be noted that by Executive Order of July 14, 1924, in cases of airships coming to the United States from foreign countries the Secretary of State should be informed in advance of the date and place of the expected arrival.

THE PALMAS ISLAND ARBITRATION

The United States and The Netherlands have agreed upon the designation of Judge Max Huber as arbitrator in the arbitration concerning the sovereignty over the Island of Palmas. The noted Swiss jurist is the President of the Permanent Court of International Justice. Mr. Fred K. Nielsen, formerly Solicitor for the Department of State and Agent and Senior Counsel in the American-British Claims Arbitration, has been appointed counsel for the United States in this case.

INTERNATIONAL CENTRAL AMERICAN TRIBUNAL

The Government of the United States has designated the following American citizens to form the list mentioned in Article III of the Convention for the Establishment of an International Central American Tribunal, signed February 7, 1923, between the Governments of the United States of America, Guatemala, El Salvador, Honduras, Nicaragua, and Costa Rica: James M. Beck, Edwin M. Borchard, J. Reuben Clark, Jr., William C. Dennis, David Jayne Hill, Manley O. Hudson, Charles Cheney Hyde, Nathan L. Miller, John Bassett Moore, Edwin B. Parker, Jackson H. Ralston, Jesse S. Reeves, James Brown Scott, George W. Wickersham, and George Grafton Wilson.

RADIOTELEGRAPH CONFERENCE

The Government of the United States has issued invitations to fortyfive governments to a Radiotelegraph Conference to be held at Washington in the spring of 1926. At the close of the International Radiotelegraph

1

Conference at London in 1912 the American delegates extended an invitation to hold the next conference at Washington in 1917. Later proposals were made with a view to holding a joint conference of parties to the International Telegraph Convention and of parties to the International Radiotelegraph Convention. As unanimity could not be obtained for these proposals, the French Government has proceeded to hold the International Telegraph Conference at Paris, beginning September 1, 1925, and the United States has taken the necessary steps to hold the International Radiotelegraph Conference at Washington in the spring of 1926. Congressional authorization for the holding of the Radiotelegraph Conference in Washington was contained in the Second Deficiency Act approved by the President on March 4, 1925, and the sum of approximately $92,000 was appropriated by Congress to defray the expenses of the conference.

The subjects to be discussed at the conference will include the revision of the International Radiotelegraph Convention and Regulations, signed at London on July 5, 1912, and the discussion of measures for the international supervision of communication by radio between the large fixed stations, broadcasting, including the handling of press messages; radio telephony; measures for the elimination of interference; distress messages so as to take cognizance of increased uses and classes of service; radio aids to navigation; and other purposes for which radio has been used as a result of the development of the art since 1912.

INTERNATIONAL LAW FELLOWSHIPS

The Carnegie Endowment for International Peace announces that Fellowships in International Law for the academic year 1926-1927 will be awarded as follows: three student's fellowships at $1,000 each; three teacher's fellowships at $1,500 each, and three fellowships for study abroad at $1,800 each. Application blanks and other information may be obtained from the Endowment's office, 2 Jackson Place, Washington, D. C. Applications will be received up to March 16, 1926.

EXTRACTS FROM THE ANNUAL MESSAGE OF THE PRESIDENT TO CONGRESS

December 8, 1925

FOREIGN RELATIONS

The policy of our foreign relations, casting aside any suggestion of force, rests solely on the foundation of peace, good will, and good works. We have sought, in our intercourse with other nations, better understandings through conference and exchange of views as befits beings endowed with reason. The results have been the gradual elimination of disputes, the settlement of controversies, and the establishment of a firmer friendship be1See note in the JOURNAL for October, 1925 (Vol. 19), p. 777.