in American waters, but wanted to ensure conflict did not escalate beyond these strictly limited objectives. As a result, it was called a "limited" or "Quasi-War" and led to political debate over whether it was constitutional. A series of rulings by the Supreme Court of the United States established its legality and confirmed the ability of the US to conduct undeclared war or "police actions". Forces and strategy Since battleships were expensive to build and required highly specialised construction facilities, in 1794 Congress compromised by ordering six large frigates. By 1798, the first three were nearly complete and on July 16, 1798, additional funding was approved for the , , and , plus the frigates and . The provision of naval stores and equipment by the British allowed these to be built relatively quickly, and all saw action during the war. The US Navy was further reinforced by so-called 'subscription ships', privately funded vessels provided by individual cities. These included five frigates, among them the , commanded by Stephen Decatur, and four merchantmen converted into sloops. Primarily intended to attack foreign shipping, these were noted for their speed, and earned huge profits for their owners; the captured over 80 enemy vessels, including the French corvette . With most of the French fleet confined to home ports by the Royal Navy, Secretary Stoddert was able to concentrate his forces against the limited number of frigates and smaller vessels that evaded the blockade and reached the Caribbean. The US also needed convoy protection, and while there was no formal agreement with the British, considerable co-operation took place at a local level. The two navies shared a signal system, and allowed their merchantmen to join each other's convoys, most of which were provided by the British, who had four to five times more escorts available. This allowed the US Navy to concentrate on attacking French privateers, most of very shallow draft and armed with between one and twenty guns. Operating from French and Spanish bases in the Caribbean, particularly Guadeloupe, they made opportunistic attacks on passing ships, before escaping back into port. To counter those tactics, the US used similarly sized vessels from the United States Revenue Cutter Service, as well as commissioning their own privateers. The first American ship to see action was the , a converted East Indiaman with 26 guns; most were far smaller. The Revenue cutter , commanded by