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Richard Chang attacks the generalization accepted by many historians that the Western consular tribunals in nineteenth-century Japan were so partial- toward West- erners and against Japanese-that they seldom rendered evenhanded justice. His study required two steps. First he tried to determine how many "mixed" cases came to trial-cases in which aJapanese brought a claim against a foreign resident in a consular court or was the complaining party in criminal proceedings against a foreigner. Between 1875 and 1895 there were five such cases that were widely reported and commented on at the time, and that have often been cited as examples. (All were decided by British consular courts.) Ten years of painstaking research led Chang to references from which he estimates that a total of about 2,800 mixed cases came before British and American consular courts, and that about 700 mixed cases came before other Western consular courts during the period of extraterritoriality-from 1859 to 1899.