Auk 
178      Rrr=R AND BENSON, "I8 ae Poor Bird De ned?"     Apil 
interesting in that it was, like ours, definitely connected with the 
nesting of the bird. 
Nor is the performance by any means restricted to the Towhee. 
Mr. Dickey, for instance, mentions that two cases of it have been 
observed in the California Linnet, and one in the Western Mocking- 
bird (Mimus p. leucopterus). From our notes the Robin (Turdu, 
migratorius) and Cardinal (Richmondena cardinalis) are mentioned 
as species in which the phenomenon has been observed. A case 
reported by C. B. Moffat in 'The Irish Naturalist,' for 1903, of a 
Blackbird (Turdus merula) thudding against a window all forenoon, 
day after day, "as monotonously as clockwork," makes specially

interesting reading because of what our Towhee has familiarized 
us with. This report of Moffat's is the more instructive from the 
fact that a Chaffinch (Fringilla coelebs) also comes into the picture. 
"So all through the spring of 1899," we read, "we had two
battles 
going on. And in the third spring, the spring of 1900, it was exactly 
the same, the "crazy Blackbird "---as he was called-fighting him-

self at one side of the house, and an equally infatuated Chaffinch 
doing the same thing at the other." 
Nor is there any doubt that many of the cursory reports that 
appear in the newspapers or are made verbally from personal obser- 
vations have a basis of fact. 
The supposition that the case we here report comes under the 
head of "defence of territory" the first part of this record furnishes

evidence that seems conclusive. But for the benefit of readers not 
familiar with the subject, a few words may be said on the idea of 
"territory" in the bird world. 
Anybody who has observed at all attentively the nesting habits 
of common wild birds, knows that with a few notable exceptions 
the nest of each pair is situated at some distance from that of any 
other pair and that while the breeding operations are going on the 
parents have a foraging ground in the vicinity of the nest, for their 
own food and that of their young. 
It is, of course, to be expected that special students of birds 
would learn more about these phenomena than common observa- 
tion could. Out of these specialized studies has come the idea of 
bird territories. Publications of the English ornithologist Howard' 
'H. Eliot Howard (a) 'Territory in Bird fe,' 1920. (b) 'An Introduction to

the Study of Bird Behavior,' 1929.