Note 434 — Chapter I · STATE TERRITORY (continued 2)
Reading edition
When, in 1909, Admiral Peary reached the North Pole and hoisted the flag of the United States the question was discussed whether the North Pole could be the object of occupation. The question must, I believe, be answered in the negative since there is no land on the Pole. See Scott in A.J. III. (1909), pp. 928-941, and Balch in A.J. IV. (1910), pp. 265-275.