The United States also argued that Palmas was United States' territory because the island was closer to the Philippines than to Indonesia, which was then held by the Netherlands East Indies. The arbitrator said there was no positive international law which favored the United States' approach of "terra firma", where the nearest continent or island of considerable size gives title to the land in dispute. The arbitrator held that mere proximity was not an adequate claim to land, noting that if the international community followed the proposed United States approach, it would lead to arbitrary results.