I the Town of Freeport v. Ringe case, why did the court conclude that Ring did not indorse the check?

1-Because he failed to sign using his last name when he signed the back of the check.

2- Because he signed "The Town of Freeport" on the back of the check

3- Because his signature only appeared on a separate, unattached piece of paper

4- because his signature on the back of the check was illegible.