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 seemed to have the advantage in its hold, by advancing upon the other while never relaxing this, forced its head backwards and at length right down upon its back, the bird so treated being obviously much distressed. At last, with a violent effort, this latter got its bill free, and the two, grappling together, and one, now, seizing hold of the other's wing, rolled together down the steep face of the rock. At the bottom they separated. The bird, as I think, that had had the worst of it all along flew back to the place from which they had fallen, while the other remained, seeming somewhat hurt by the fall. Some time later there was another conflict between the same two gulls which was similar in all respects, including the place at which it was fought, except in its ending. This time there was no fall down the rock, but the one bird flew off, soon, however, to alight again, the other one pursuing and continuing to molest it with savage sweeps from side to side."

No doubt, in a fight like this, each bird seizes the other by the beak, as fearing what it might otherwise do with it, as two men with knives might seize hold of each other's wrists. But this might become in time so confirmed a habit that the birds, when fighting, would have no idea of doing anything else, and thus not attack each other in any less specialised way, however much one might have the other at an advantage. I do not mean to say that it has really come to this with the gulls in question—the facts, indeed, do not bear out this view—but several times, when watching birds fighting, I have seen, as I believe, a tendency in this direction, and it has occurred to me that the process might be carried even further.