Footnote

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Literally, the word “territory”, as here used, signifies property, since the language is not “territory or property”, but “territory or other property.” There thus arises an evident difference between the words “the territory” and “a territory” of the United States. The former merely designates a particular part or parts of the earth's surface-the imperially extensive real estate holdings of the Nation; the latter is a governmental subdivision which happened to be called a “territory”, but which quite as well could have been called a “colony” … “province” … ‘A territory, under the Constitution and laws of United States is an inchoate [incomplete] state,” quoting Ex parte Morgan D.C. 20 Fed 298, 305. O'Donoghue v. United States, 289 US 516, 537 (1933) [explanation added]