In the first of the United States' two arguments, it claimed to hold the island because it had received the actual title through legitimate treaties from the original "discoverer" of the island, Spain. The United States argued that Spain acquired the title to Palmas when she discovered the island and that the island was "terra nullius". Spain's title to the island, because it was part of the Philippines, was then ceded to the United States in the 1898 Treaty of Paris (1898) after Spain's defeat in the Spanish–American War. The arbitrator noted that no new international law invalidated the legal transfer of territory via cession.