Many terns and sandpipers lay their eggs on the bare sand of the sea-shore, and no doubt the Duke of Argyll is correct when he says, that the cause of this habit is not that they are unable to form a nest, but that, in such situations, any nest would be conspicuous and lead to the discovery of the eggs. The choice of _place_ is, however, evidently determined by the habits of the birds, who, in their daily search for food, are continually roaming over extensive tide-washed flats. Gulls vary considerably in their mode of nesting, but it is always in accordance with their structure and habits. The situation is either on a bare rock or on ledges of sea-cliffs, in marshes or on weedy shores. The materials are sea-weed, tufts of grass or rushes, or the _debris_ of the shore, heaped together with as little order and constructive art as might be expected from the webbed feet and clumsy bill of these birds, the latter better adapted for seizing fish than for forming a delicate nest. The long-legged, broad-billed flamingo, who is continually stalking over muddy flats in search of food, heaps up the mud into a conical stool, on the top of which it lays its eggs. The bird can thus sit upon them conveniently, and they are kept dry, out of reach of the tides. Now I believe that throughout the whole class of birds the same general principles will be found to hold good, sometimes distinctly, sometimes more obscurely apparent, according as the habits of the species are more marked, or their structure more peculiar. It is true that, among birds differing but little in structure or habits, we see considerable diversity in the mode of nesting, but we are now so well assured that important changes of climate and of surface have occurred within the period of existing species, that it is by no means difficult to see how such differences have arisen. Simple habits are known to be hereditary, and as the area now occupied by each species is different from that of every other, we may be sure that such changes would act differently upon each, and would often bring together species which had acquired their peculiar habits in distinct regions and under different conditions. _How do Young Birds learn to Build their First Nest?_