occurred before the detention by the British authorities of the
Wilhelmina and her cargo of foodstuffs, which the German Government
allege is the justification for their own action.

"The Germans have announced their intention of sinking British merchant
vessels by torpedo without notice and without any provision for the
safety of the crews. They have already carried out this intention in the
case of neutral as well as of British vessels, and a number of
non-combatant and innocent lives on British vessels, unarmed and
defenseless, have been destroyed in this way.

"5. Unfortified, open, and defenseless towns, such as Scarborough,
Yarmouth, and Whitby, have been deliberately and wantonly bombarded by
German ships of war, causing in some cases considerable loss of civilian
life, including women and children.

"6. German aircraft have dropped bombs on the east coast of England,
where there were no military or strategic points to be attacked. On the
other hand, I am aware of but two criticisms that have been made on
British action in all these respects:

"1. It is said that the British naval authorities also have laid some
anchored mines on the high seas. They have done so, but the mines were
anchored and so constructed that they would be harmless if they went
adrift, and no mines whatever were laid by the British naval authorities
till many weeks after the Germans had made a regular practice of laying
mines on the high seas.

"2. It is said that the British Government have departed from the view
of international law which they had previously maintained, that