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1 See editorial comment by James, W. Gamer, this JOURNAL, Vol. 32 (1938), pp. 106–113 Google Scholar.
2 “The right to treat unlawful and unauthorized warfare as piratical, seems to me, therefore,clearly imbedded in the very roots of international law.” The Ambrose Light, 25 F. 408 (1885). The court is here dealing with an unrecognized insurgent group.