Initially, they sang only at dawn and dusk and spent much time squabbling while establishing territories at either end of our garden.

If unsuccessful in these ventures, and most are, they establish territories in canopy gaps among tall trees in the afternoons.

On arrival at their breeding grounds they establish territories.

Birds that arrive early and establish territories appear to have an advantage over those that arrive later in the winter areas.

In order to avoid overwhelming tourists or shoppers, ambulantes are known to establish territories and limit their numbers.