and Migration of North American Birds," is emphatic that the transfer of American birds to Europe is entirely due to the agency of winds carrying them from their course (6). Mr A. L. Butler met with snow-buntings in mid-Atlantic travelling east, and Mr J. Trumbull supplies information about many passerine birds—especially snow-buntings and wheatears—seen in September and October at various points between Canada and the British coasts (53). Some joined ships but others made no attempt to do so, even at 54" north 44° west.
Unfortunately there is the negative evidence of fraud, for when unscrupulous dealers found that the public would give high prices for rare birds, a trade in American skins began. It is not impossible that even Gätke was victimised. Error or even accidental fraud may be taken into account. Some years ago I heard that a hawk-owl had been killed in Cheshire, at an inland port on the Ship Canal; I traced the bird, the American species, but discovered that it had been captured on an east-bound steamer in the Straits of Belle Isle, and had only died or been killed when the vessel reached the cooling station at Partington, where the taxidermist who received it thought it had been taken. A Cape pigeon, which I saw in the flesh, reported as shot in Lancashire, I found had been brought home in cold storage.
