Sylvain Attempted to Draft a Cheque in Payment of a Stereo

Sylvain attempted to draft a cheque in payment of a stereo that he wanted to purchase. A court subsequently held that the cheque was invalid. That may be TRUE because

A) Sylvain used a pencil rather than a pen.
B) Sylvain wrote the name of a fictional person in the space allocated to the name of the payee.
C) Sylvain did not fill in the name of the payee.
D) the cheque was postdated.
E) the amount was said to be "a reasonable price for the stereo."