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*Autocephaly by its nature includes a total territorial definition, which Moscow's [[tomos]] does not make, especially because it kept dozens of parishes for itself in North America and makes no claim over the majority of Orthodox parishes in America. This is a "paradox... unheard of in the Orthodox chronicles" (p. 51).
*No autocephalous Church may extend its jurisdictional boundaries without the consent of the whole Church (in Russia's case, those boundaries were defined in 1591).
*Autocephaly must require the full agreement of the people and leadership in the territory in question, but the OCA's autocephaly only required represented the agreement of a minority of Orthodox America. St. [[Tikhon of Moscow]] said this regarding the [[Church of Georgia]], that its autocephaly must be "the universal and fully agreed upon wish of the people" (p. 49).
*Right to jurisdiction does not follow from setting up a bishop; rather, setting up a bishop follows from prior agreed upon jurisdiction: "it is the undoubted jurisdictional rights over a territory that constitute the indispensable condition for the right to appoint a bishop, not the claiming of jurisdictional rights as a result of having appointed a bishop there. The appointment and establishment of a bishop in a particular place cannot be used as a means of jurisdictionally annexing that place" (p. 55).
*"We wonder how the Church which first established a bishop in Sitka, San Francisco, or elsewhere on this vast continent, could attempt to jurisdictionally subjugate this whole country. Certainly you are not ignorant of the fact that America is larger and of larger population than Europe, and also of the fact that the Ecumenical Synods decreed with precision on the boundaries and other jurisdictional matters of sparcely [''sic''] populated communities and even villages" (pp. 55-56).
*"...even if it appears to some that these territoris territories [i.e., North America] are under the jurisdiction of no one, one thing is certain that they are not under the jurisdiction of the Patriarchal Throne of Moscow," but that "The holy Canons have clearly decreed that, 'the Churches of God in the barbaric nations are governed according to the tradition of the Fathers' [i.e., their mother churches, referencing Canon 150 of the 2nd Ecumenical Council]" (p. 59).*"The title, mother-Church, as the inspired 150 Fathers implicitly signified, is only a sign of honor, of no rights whatsoever. The Church in Jerusalem never exercised any authority on the rest of the Churches... even though it was from there that all of the Godly Apostles who attracted and tutored us to the state of obedience of Christ set off" (p. 62).
===Historical arguments===
*The first Orthodox parish established on American soil was by Greeks in New Orleans, Louisiana, in 1864, three years before Alaska became American and four years before the first Russian parish was established in American territory (in San Francisco).
*The claim that each autocephalous church may grant autocephaly to its daughter churches contradicts Russian history, in which Russia claimed independence for itself more than 150 years before Constantinople and the rest of the Church recognized it: "If the autocephalous status derives from Christ, why was the Russian Orthodox Greek Catholic Church in America anathematized by you instead of being approved and praised for severing itself from its Patriarchate and its mother Church—as some other Churches did too—by right of its own will and against the Canons?" (p. 61).
===Practical arguments===
