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196/ Regarding the history of native claims in Alaska, see generally United States v. Atlantic Richfield Co., 435 F. Supp. 1009, 1014-1019 (D. Alaska, 1977), aff'd 612 F.2d 1132 (9th Cir. 1980), cert, denied, 449 U.S. 888 (1980).

197/ One commenter states that the United States acquired fee title to over fifty percent of the land in Hawaii upon annexation and that, by contrast, the Federal Government obtained fee title to much less than fifty percent of the land in Alaska when it purchased Alaska in 1867. In fact, by the Treaty of Cession in 1867, the United States acquired well over 90% of the land in Alaska, and continues to hold over 90% of Alaska land.

198/ Alaska Statehood Act, P.L. No. 85-508, 72 Stat. 339, as amended, 73 Stat. 141, 48 U.S.C. Chapter 2.


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