Such "appurtenant," dependent or unincorporated territory is, of course, from the international point of view a part of the United States,1 but is not, as we shall see, a part thereof in the

1 This international use of the term United States is considered in the case of De Geofroy v. Riggs (133 U. S. 258; 10 Sup. Ct. Rep. 295; 33 L. ed. 642), in which the question involved was whether the terms of a treaty giving to citizens of France the right to inherit an interest in real estate in "States of the Union," were applicable to the District of Columbia or only to the States of the Union. The use of the phrase "States of the Union" would upon its face indicate that only the States and not the extra-State areas were concerned, yet the court held that the treaty was to be construed as generally applicable. In its opinion the court said: "This article is not happily drawn. It leaves in doubt what is meant by "States of the Union." Ordinarily these terms would be held to apply to those political communities exercising various attributes of sovereignty which compose the United States, as distinguished from the organized municipalities known as Territories and stricter constitutional sense in which the term is used in the Constitution with reference to certain limitations which that instrument lays upon the legislative powers of Congress.