Bonaparte (1857: 224) listed " Gavina hinc Larus kamtschatschensis Bp. " in the synonymy of Larus niveus Pallas. The name is thus not available for nomenclatural purposes (Art. 11.6 of the Code) and the provisions of Art. 11.6. 1 of the Code do not apply, because the name was already published in earlier works (Bonaparte 1855: 16, 1856: 771). In spite of this, Bonaparte's (1857) kamtschatschensis was used as a valid name for the taxon in recent literature (see above for citations), probably following Peters (1934: 315, footnote) who argued that “a quotation [of a name in the synonymy of an available name] ipso facto renders the name a substitute name for the species in whose synonymy it is quoted. His argument does not match provisions of the Code (ICZN 1999).