The depositing of courtship offerings before men by the Penguins shows us that there must be a certain freedom of mental connection in birds. Here an act, properly belonging to courtship, is performed as the outlet, as it were, of another and unusual emotion. The same is seen in many song-birds, who, like the Sedge Warbler, sing loudly for anger when disturbed near their nest; or in the Divers, who, when an enemy is close to the nest, express the violence of their emotion by short sharp dives which flip a fountain of spray into the air--a type of dive also used as a sign of general excitement in courtship. Or, again, the actions may be performed for their own sake, as we may say: because their performance, when the bird is full of energy and outer conditions are favourable, gives pleasure. The best-known example is the song of song-birds. This, as Eliot Howard has abundantly shown, is in its origin and essential function a symbol of possession, of a nesting territory occupied by a male--to other males a notice that “trespassers will be prosecuted,” to females an invitation to settle, pair, and nest. But in all song-birds, practically without exception, the song is by no means confined to the short period during which it actually performs these functions, but is continued until the young are hatched, often to be taken up again when they have flown, or after the moult, or even, as in the Song Thrush, on almost any sunny or warm day the year round. And finally this leads on to what is perhaps the most interesting category of birds’ actions--those which are not merely sometimes performed for their own sake, although they possess other and utilitarian function, but actually have no other origin or _raison d’être_ than to be performed for their own sake. They represent, in fact, true play or sport among ourselves; and seem better developed among birds than among mammals, or at least than among mammals below the monkey. True that the cat plays with the mouse, and many young mammals, like kittens, lambs, and kids, are full of play; but the playing with the mouse is more like the singing of birds outside the mating season, a transference of a normal activity to the plane of play; and the play of young animals, as Groos successfully exerted himself to show, is of undoubted use. To be sure, the impulse to play must be _felt_ by the young creature as an exuberance of emotion and spirits demanding expression; but a similar impulse must be felt for all instinctive actions. Psychologically and individually, if you like, the action is performed for its own sake; but from the standpoint of evolution and of the race it has been originated, or at least perfected, as a practice ground for immature limbs and a training and keeping ready of faculties that in the future will be needed in earnest.